Study · built 30 September 2026 · JR Barbieri

$83.7 billion of excess distributions reached their fifth and final year unused. $4.7 billion was applied that year; $79.0 billion (94%) was not.

When a private foundation pays out more than its distributable amount (the year's 5% payout, after taxes), the excess is a credit it can apply against the next five years' amounts. It is not cash: when the fifth year ends unused, no money leaves the foundation; it loses the credit. A carryover is applied only to the part of a year's amount that the year's own distributions do not meet, so a foundation that keeps paying above its amount never draws on it. On their latest returns, 3,274 foundations show $21.2 billion of excess in its fifth and final year.

Measured from filed returns, periods ending 2016 to 2026. Not tax or legal advice.

The figures

What carries, and what reaches year five.

$79.0 billionof $83.7 billion reaching a fifth and final year, not applied by the end of it

4,520foundations with an excess not applied by the end of its fifth year, at least once, of the 10,947 whose latest return carries Part XII

$21.2 billionin its fifth and final year, shown by 3,274 foundations on their latest returns

$125.4 billioncarried forward on the latest returns of 6,093 of 10,947 foundations

Year the return's period ends	Excess not applied by the end of its fifth year
2018	$3.6 billion
2019	$466 million
2020	$11.8 billion
2021	$13.6 billion
2022	$13.6 billion
2023	$14.8 billion
2024	$16.5 billion
2025	$4.6 billion
2026	$29 million

Periods ending in 2018, 2019, 2025 and 2026 are partial: the IRS's e-file data is thin before 2020, and most returns for periods ending in 2025 and 2026 were not yet filed or published when the study was built. A 2026 row comes from fiscal-year and short-year returns whose period has already ended. The 17 returns for periods ending in 2016 and 2017 report no excess not applied, so they have no row.

Method

How each figure is made.

The population

The 11,842 private foundations in the directory, each with at least $10 million in assets when the directory was built, and every e-filed Form 990-PF the IRS has published for each: 65,637 returns. 10,947 of them have a latest return that carries Part XII (private operating foundations do not).

The excess

Part XII of each return re-done, and each year's opening carryover held against the prior year's closing, so an excess is followed year by year until it is applied or reaches its fifth year.

Not applied by the end of its fifth year

Part XII, line 8 as each return reports it: the part of the excess from five years back that the year did not use. The excess arriving in its fifth year is the oldest year's excess the return carries in (Part XII, line 3a, as each return reports it), so both sums, and the share between them, are on the filers' own figures. The line-by-line recomputation is shown on each foundation's record page; the totals here use the filers' figures.

What it cannot see

A return filed on paper; an amendment not yet published by the IRS; a foundation outside the directory.

The file

The totals are in the data file (CC BY 4.0).

Cite as: Barbieri, J. “Excess Distribution Carryover After Five Years.” The ParetoAlpha Library, study, built 30 September 2026. https://paretoalphasystems.com/research/fifth-year-2026

Asked often

What happens to excess distribution carryover after five years?

An excess not applied within five tax years can no longer be applied. Part XII, line 8 of Form 990-PF shows the amount from five years back that is no longer carried.

What is an excess distribution carryover?

When a private foundation's qualifying distributions in a year exceed its distributable amount, the excess carries forward and can be applied against the distributable amount of the next five tax years. Part XII of Form 990-PF tracks each year's excess separately.

Can an excess be extended past its fifth year?

No. The IRS's page on distribution carryovers of private foundations (reviewed by the IRS 28 June 2026) says an election to treat a year's distributions as made out of corpus does not carry an excess past its fifth year.

Does an unapplied excess mean a foundation did something wrong?

No. It means distributions above a year's distributable amount were not later counted against another year's. The figure describes the record, not anyone's decisions.

Which foundations are counted?

The 11,842 private foundations in the directory built 26 September 2026 (each had ten million dollars or more in assets when the directory was built; 98 had fallen below that by their latest return), and every e-filed Form 990-PF the IRS has published for them: 65,637 returns. No foundation is named and no EIN is published.

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One foundation's carryover, year by year.

Type its name or EIN. Its filed returns appear on screen with Part XII re-done for each year. Free, in seconds; no account.

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Full study: each excess followed year by year.