On April 18, 2012, the Internal Revenue Service (IRS) released new guidance on the program-related investments (PRIs) of private foundations. Although the proposed regulations – which provide nine new examples of investments that qualify as PRIs – do not break substantial new ground from a practice perspective, they do provide clear regulatory approval of certain principles and structures that have become well established among PRI makers and practitioners in this area.

The proposed regulations also modernize the existing PRI examples and are more reflective of the types of charitable investments occurring today.

The new examples embody the following principles...