Analysis and guidance on Section 25F
In-depth posts on regulatory developments, formation strategy, state news, and operational guidance for organizations building and running scholarship programs.
Section 25F Proposed Rules: What SGOs Need to Know Before Finalizing Their Structures
The IRS has signaled its intent to issue proposed regulations under Section 25F. Here is what the current statutory text requires, where the regulatory gaps are, and what SGOs should be doing now rather than waiting.
Form Your Own SGO or Partner With an Existing One? A Framework for the Decision
The decision to form a new SGO versus partner with an existing one is strategic, not just operational. Here is the framework we use with organizations that are evaluating their options.
How to Run a Compliant Scholarship Award Process Under Section 25F
The no-earmarking rule and the arm's-length award requirement are the most operationally demanding compliance requirements in Section 25F. Here is what a compliant award process actually looks like.
State SGO Opt-In Status: What We Know As of Spring 2026
Which states have enacted qualifying Section 25F opt-in legislation, which are actively considering it, and what organizations in non-opted states should be doing right now.
The 90/10 Rule: How to Maintain Compliance From Your First Scholarship Cycle
Section 25F requires that SGOs spend at least 90% of their annual revenue on qualified scholarships. The rule sounds simple. The operational implications are not.
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