Research · 2026-09-28

11,842 foundation returns, re-done line by line.

Every private foundation with at least $10M in assets and an e-filed 990-PF: $1.70 trillion between them. Each latest return was read from the IRS's own file and re-done by the code behind every proof page. In 11,827 of them (99.9%), every line we recompute agrees.

The arithmetic

The returns add up. Almost all of them.

99.9%minimum investment returns that recompute from the return's own assets (6 differ)
99.9%excise tax lines that recompute from the return's own investment income (8 differ)
100.0%distributable amounts that recompute through the form's own chain (1 differs)

“Recomputes” includes the form’s whole-dollar rounding and a short tax year’s proration. A line that differs is the return’s figure beside the recomputed one; the return may carry a reason the file does not show, such as a schedule filed on paper or an election. It is a fact of the comparison, not a conclusion about the foundation. 15 returns carry one such line:

  • 8: excise tax filed as zero
  • 5: a short year the return does not prorate
  • 2: other

A short tax year has two official readings: the Treasury regulation divides by 365 days (§53.4942(a)-2(c)(5)(iii)); the IRS’s instructions for Part IX, line 6 divide by 366 in a leap year. The engine accepts either, tries the regulation first, and each proof page names the rule the return used. 21 returns follow the instructions’ 366 days.

The payout

$19.7B carried into the next year.

A year’s distributable amount may be paid through the end of the following year, so what a return carries is owed, and dated, but not late. 4,821 of the 10,807 foundations the form measures carry some into the next year, in Part XII.

1.02×the median foundation's qualifying distributions, against its distributable amount for the year
47%paid less than the year's distributable amount within the year, which the form allows to be met the next year
5.0%the median payout as a rate of net noncharitable-use assets; the legal test is the amount, not the rate

Measured where the form measures it: a domestic, non-operating foundation with a distributable amount above zero (10,807 returns). The middle half of them paid between 0.90× and 1.38× the year’s amount.

The holdings

More than half list their stock as one line.

6,513 returns (55%) report corporate stock as a single total, not a list, so what the foundation holds cannot be read from its own return. The other 5,329 list their holdings, and the list adds to the total.

By size

The larger the foundation, the less of it is listed stock.

AssetsFoundationsAssets between themMedian payout ×Median in listed stockMedian in other investments
$10M–$75M9,004$262.9B1.01×51%6%
$75M–$250M1,867$241.2B1.02×44%17%
$250M–$1B651$306.6B1.02×36%28%
Over $1B172$885.3B1.02×12%56%

Shares are of total assets at fair market value, Part II. “Other investments” (line 13) is where a return reports funds, partnerships and alternatives. The median foundation under $75M holds 51% in listed stock; over $1B, 12%.

How it was done

The same code as every proof page. Check any line.

  • The population: every private foundation in the IRS e-file index with at least $10M in assets, as of 2026-09-26 (11,842 foundations); its latest e-filed return (tax years ending mostly in 2024 and 2025), read from the IRS’s own published file and checked byte for byte.
  • Each return re-done with exact decimal arithmetic by the engine behind every sealed proof page. Nothing is estimated and nothing is sampled.
  • Any foundation’s figures can be reproduced by sealing its return: type its name, and the proof page shows every line as filed beside the line recomputed.
  • Totals only. No foundation is named here, and nothing here judges a filing date; the nine controls state dates and nothing else.
  • The totals are published as data under CC BY 4.0. The IRS data is public domain. Cite as: ParetoAlpha, “The 990-PF, Re-Done,” 2026-09-28.
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