Summary

Allows qualified charitable organizations to make grants for collegiate housing and related infrastructure to student housing entities and social clubs without automatically losing their tax-exempt charitable or educational treatment. The change defines what counts as a collegiate housing and infrastructure grant, what property qualifies as collegiate housing (residents must be substantially all full‑time students), excludes grants used to provide physical fitness facilities, and treats certain title‑holding entities as pass‑through recipients. The rule applies to grants made in taxable years ending after enactment.

Key Points

• Permits qualifying charities to make grants for collegiate housing and infrastructure without automatically losing tax-exempt charitable/educational status.
• Specifically allows grants to 501(c)(7) social clubs (and title-holding entities acting for their benefit) to be treated as acceptable charitable activity.
• Defines "collegiate housing and infrastructure grant" as support to provide, improve, operate, or maintain collegiate housing property, but excludes funding for physical fitness facilities.
• Defines collegiate housing property by requiring that residents be substantially all full‑time students of the local college or university at the time of the grant or after financed changes.
• Applies prospectively to grants made in taxable years ending after enactment.
• Requires documentation and compliance by charities to rely on the nonjeopardy rule; IRS guidance or review may follow.
• Does not create a federal spending program or appropriate funds; it amends tax treatment under the Internal Revenue Code.
• Could enable additional private funding for student housing projects, including by social clubs affiliated with student groups or alumni organizations.

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