定義
A program-related investment is a foundation's concessionary loan, equity stake, or guarantee made primarily to advance charitable purposes rather than to generate market-rate financial returns.
Program-related investments, universally abbreviated as PRIs, allow private foundations to deploy capital in ways that look like investing but are driven by mission. A PRI might be a below-market loan to a nonprofit affordable-housing developer, a loan guarantee enabling a community health clinic to borrow, or an equity investment in a social enterprise that would not attract conventional capital. The key test is that the primary purpose must be charitable, not profit-seeking, and the investment must not support activities that would be taxable lobbying or political activity.
PRIs matter to wealthy families because they can count toward a foundation's minimum distribution requirement. This means a foundation can deploy charitable dollars in a recoverable form. If a loan is repaid, those funds cycle back and can be re-granted, rather than making outright grants that leave permanently. That recycling potential is one of the structure's more discussed potential advantages.
A hypothetical foundation might make an illustrative $2 million below-market loan to a rural broadband cooperative, counting it as a qualifying distribution for that year. When repaid, the foundation has fresh capital to deploy again.
PRIs are often confused with mission-related investments, which are quite different in structure and purpose. PRIs are explicitly charitable acts; MRIs are ordinary investments shaped by values. A qualified attorney and CPA should structure any PRI to ensure it meets IRS requirements.
最終レビュー日 August 25, 2026 · 編集方針