Title 26 › Subtitle Subtitle D— - Miscellaneous Excise Taxes › Chapter CHAPTER 42— - PRIVATE FOUNDATIONS; AND CERTAIN OTHER TAX-EXEMPT ORGANIZATIONS › Subchapter Subchapter H— - Excise Tax Based on Investment Income of Private Colleges and Universities › § 4968
Certain private colleges and universities must pay a yearly tax on their net investment income if their endowment per student is at least $500,000 and they meet size and location tests. The tax rate depends on how big the endowment is per student: 1.4% for $500,000–$750,000, 4% for more than $750,000 up to $2,000,000, and 8% for over $2,000,000. To owe the tax, a school must have had at least 3,000 tuition‑paying students the year before, more than half of its tuition‑paying students in the United States, and not be a state college or university. Short definitions: “student adjusted endowment” = value of assets not used directly for the school’s exempt activities divided by number of students; “number of students” = daily average full‑time equivalent enrollment; “net investment income” = calculated like the private‑foundation rules and it includes interest from student loans and royalties tied to federal funding; “related organization” = groups that control or are controlled by the school or that the school supports, whose assets and income may be counted with limits. The Secretary must make rules to stop attempts to avoid the tax, including by rearranging endowments.
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Internal Revenue Code — Source: USLM XML via OLRC
Legislative History
Reference
Citation
26 U.S.C. § 4968
Title 26 — Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73