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.
Qualified Contributions vs. Operating Gifts: The Two-Gift Structure That Funds an SGO
Every SGO plan stalls on the same sentence: who pays for the staff? The 10% allowance is not the only money available — it is only the money that comes out of the accounts. Section 25F qualified contributions and ordinary Section 170 operating gifts are two separate instruments, and running both is the difference between a budget that works and one that does not.
Can You Use an Existing 501(c)(3) as Your SGO — and Just Register It in Every State?
Nothing in Section 25F requires a new entity, so the legal answer is yes. The practical answer is usually no, and it comes down to one sentence in Treasury's June preview about how the 90 percent test is measured. Here is the full analysis — the four things your organization's history brings with it, why 'register in every state' is a different question than it sounds, and what to settle before the proposed regulations land at the end of September.
Will Michigan Opt Into the Education Freedom Tax Credit? What Michigan Schools Should Do Now
Michigan sits in the studying column: no election filed, a governor waiting on federal guidance, and a State Board that voted to urge non-participation. There are two live decision points, not one — a lame-duck window that closes January 1, 2027, and the November 3 election that seats whoever decides about 2028. Neither of them changes what a Michigan school should be doing this fall.
Starting an SGO: Who Is Actually Going to Run It?
Forming a Scholarship Granting Organization is a project with an end date. Operating one is a job with no end date, and it is the half nobody costs out. Here is the real week-to-week work, and the three honest ways to get it done: staff it yourself, own the SGO and outsource the operation, or join one that already runs.
The Nine Questions the September Education Freedom Tax Credit Regulations Must Answer
Treasury has committed to proposed regulations by the end of September 2026. Nine questions are genuinely unresolved, and each one changes something an SGO has to build. Here is every question, what the June preview already told us, and how to design so that either answer leaves you compliant.
State Opt-In Status: 30 States Are In for 2027
The IRS updated its participating-state list on July 24, 2026: thirty states have now filed an advance election for 2027, up from twenty-seven in June. Here is the full list, the three states that moved and why, the announced-but-not-filed column, and the thing the headline count does not tell you — that no SGO is federally listed anywhere yet.
Can a Single School Join an SGO? Yes — and Here Is Exactly How It Works
One campus is the hardest case in the entire federal scholarship tax credit program, because the statute will not let an SGO fund only your students. Joining an SGO that already operates solves that structurally. Here is what your school actually does, what your families experience, what you can never promise, and what it costs.
How to Choose the SGO Your School Joins: Twelve Questions
Deciding to join an SGO instead of forming one is the easy half. The harder half is picking which SGO — because the one you choose holds your families' scholarship money, decides who gets it, and puts your school's name on the giving page. Here are the twelve questions to ask, the documents to request, and the answers that should end the conversation.
Three Ways In: Start Your Own SGO, Have Us Run It, or Join One
Every organization looking at the federal scholarship tax credit lands on the same fork: build the Scholarship Granting Organization yourself, or join one that already exists. There is a third answer between them — own the SGO and let somebody else operate it. Here is the honest comparison, and the three questions that usually settle it.
How a Single School Starts Its Own SGO — and the Rule That Decides Whether It Should
A single school can absolutely form a scholarship granting organization. What it cannot do is use it the way most single schools are imagining. One sentence in the statute — ten or more students who do not all attend the same school — reshapes the entire project, and it is better understood before incorporation than after.
Does Taking Education Freedom Tax Credit Money Put Your School Under Federal Regulation?
It is the first question a Christian school board asks, and it usually gets an answer that is either too reassuring or too alarming. Here is the structural answer: what the enacted statute actually conditions, why the money is treated as private, the precedent that should give you pause, and the four places real exposure sits.
The Consortium SGO: One Scholarship Organization Across Schools That Compete
A diocese has a hierarchy to settle the hard questions. An association of independent Christian, classical, or private schools does not — its members are peers who recruit from the same families. That single difference reshapes governance, allocation, and cost sharing. Here are the five decisions that determine whether a consortium SGO holds together.
How Much Scholarship Money Could the Federal Credit Unlock in Your State?
The federal scholarship tax credit has no statewide cap and no appropriation — its size in each state is set by donor participation alone. That makes the market math simple enough to run on a napkin: taxpayers, times participation rate, times $1,700. Here is the formula, the honest benchmarks, and what the arithmetic says about holdout states.
What It Actually Costs to Run an SGO: Hours, Dollars, and Who Does the Work
Formation gets budgeted. Operation almost never does. The 10% administrative allowance is a ceiling, not a budget, and in year one it is a ceiling on a number that has not arrived yet. Here is a planning model you can run with your own assumptions — the revenue ceiling, the work by function, the costs by category, and which pool each one comes from.
The Diocese Playbook: Standing Up a Scholarship Organization Across Dozens of Schools
The federal scholarship tax credit's hardest structural rules — multi-school distribution, no earmarking, arm's-length committees — are existential problems for a single parish and nearly free for a diocese. Here is how a diocese or statewide Catholic conference should structure its scholarship organization, and the handful of decisions that determine whether it works.
Already Running a State Tax-Credit Scholarship Program? What the Federal Credit Changes for You
The organizations best positioned for the new federal scholarship tax credit are the ones already running state programs — Georgia's SSOs, Indiana's SGOs, Iowa's STOs, Florida's scholarship organizations. But the federal credit is not an upgrade to your state program. It is a parallel program with different donors, different rules, and a different pitch.
You Don't Have to Live in a Participating State to Claim the $1,700 Scholarship Tax Credit
The Section 25F credit is available to any U.S. taxpayer — eligibility turns on where the SGO is listed and where the student resides, not where the donor lives. For donors in states that haven't opted in, that asymmetry opens a real giving path on January 1, 2027, with honest trade-offs worth understanding.
The 90/10 Rule Is a Withdrawal Cap, Not an Expense Rule — and It Rewrites SGO Fundraising Math
The most useful reframe in SGO operations: the 90/10 test governs what leaves each state account, not where your costs sit. Released funds pool and become fungible — but the cap binds per account, which makes any fundraising that doesn't return 10:1 in the same state effectively unfundable from scholarship money.
Do Credit Card Fees Count Against Your SGO's 10%? The Payment-Rail Problem Nobody Is Pricing In
Under the general rule Treasury previewed, the 90% test is measured against receipts unreduced by expenses — which means payment processing fees compete for the same 10% that has to cover staff, audit, and everything else. At scale, card fees alone can consume a quarter of an SGO's entire administrative allowance. The fix is architectural.
Selection Committees and Disqualified Persons: The Family Cost of an SGO Committee Seat
Treasury expects Section 25F regulations to treat selection committee members — and their immediate families — as disqualified persons who cannot receive scholarships from the SGO. For school communities, that means committee seats carry a real family cost, and committee architecture deserves board-level attention before anyone is seated.
One Entity, Many State Accounts: How Multistate SGOs Actually Work Under Section 25F
Can an SGO operate nationally? Yes — but 'national SGO' is a misleading label. Section 25F permits one 501(c)(3) to be listed by many states, with a separate segregated account per state, money locked to the state the donor designates, and the 90/10 test running account by account. Here is the full structure.
The Section 25F Safe Harbor: Why the 90% Test Nearly Broke Every Diversified Nonprofit — and What Changed in June
Under IRS Notice 2025-70, the 90% scholarship-spending test would have been measured against an organization's entire income — dues, program fees, everything. Treasury's June preview replaced that with a safe harbor measured on the segregated account. Here is how it works, who qualifies, and the structural decision it forces.
Treasury's June 2026 Section 25F Preview: Every Item, Explained
On June 9, 2026, Treasury previewed the regulations it intends to propose under Section 25F — the safe harbor for the 90% test, the multistate account rules, the audit requirement, the unique donor number, and more. This is the complete item-by-item walkthrough, including what remains unanswered.
Why Most SGOs Get Scholarship Disbursement Wrong — And What a Compliant System Actually Looks Like
Approving a scholarship is the easy part. Getting the funds where they need to go in a way that creates an airtight compliance record is where most SGOs accumulate serious liability. The default approach — hand the family the money and collect receipts later — breaks at scale. Here is what compliant disbursement actually requires, and why the answer is not a single payment method.
Faith Communities and Section 25F: The Compliance Tensions Unique to Religious Organizations
Faith communities are among the most active SGO organizers — and the ones who face the most distinctive compliance challenges. The earmarking tension, single-school concentration, and governance independence questions all hit harder in a congregation context than anywhere else in the program.
The SGO Compliance Calendar: What Your Organization Must Do Every Month and Year
Compliance for a Section 25F SGO is not a once-a-year filing exercise. It is an ongoing operational discipline. Here is what your organization needs to do monthly, quarterly, and annually to stay compliant and keep your approved status.
The $1,700 Federal Scholarship Tax Credit: A Complete Guide for Donors
The federal scholarship tax credit (Section 25F) is a dollar-for-dollar reduction in your federal income tax bill — not a deduction. Here is exactly how it works, what you need to claim it, and what the $1,700 limit means in practice.
SGO Scholarship Eligibility: How the 300% AMI Requirement Works in Practice
Section 25F scholarships are restricted to students from households earning at or below 300% of area median gross income. The rule sounds simple. Applying it correctly requires understanding what AMI means, how it varies by location, and what documentation your SGO needs to collect.
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.
What Can Section 25F SGO Scholarships Pay For? A Guide to Qualified Expenses
Section 25F scholarships can only be used for qualified educational expenses as defined by the Coverdell Education Savings Account rules. The list is broader than tuition — but it has real limits. Here is what qualifies, what does not, and where the gray areas are.
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.
SGOs, ESAs, and Vouchers: Understanding the Three Models of School Choice
Section 25F SGOs are one of three major structures used to fund private K-12 education with public dollars or tax benefits. Understanding how SGOs compare to Education Savings Accounts and traditional vouchers clarifies when each model makes sense and what makes Section 25F distinctive.
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.
Know the moment your state moves.
Opt-in legislation is moving through statehouses right now. Tell us your state and we’ll send a short email when its status changes — plus formation deadlines and program guidance as January 1, 2027 approaches.
Talk it through before you decide.
Tell us about your organization and we’ll set up a consultation on your formation path, your state, and the timeline. It costs nothing and there is nothing to sign — and if it’s useful, we’ll walk through the platform on the same call.
What happens next
We read your submission and respond within one business day
A working session, typically 45–60 minutes — your situation, not a sales pitch
Which of the three paths fits, what your state requires, and what the timeline is
You leave with a clear recommendation — including when the answer is to join an SGO rather than form one, or to wait