EFTA00598056Set 9
2011-02-1415p11,023w
elan Foundation (Foundation) of an account that the materials characterized as a
"donor advised fund" or 'family public charity (Foundation account), by means of which a donor's donations
would ... account.
On May 12, 1998, petitioner submitted an "Application To Establish a Donor Advised Fund" to the
Foundation, designating himself as the "fund advisor. Petitioner signed the application under ... Fund Advisor Statement", which stated:
I certify that I understand the nature of donor advised funds and will conduct activities which satisfy
the requirements of the Internal Revenue Code
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598056.pdf
EFTA01090583Set 9
2006-08-175p2,805w
Pension Protection Act of 2006 (PPA) includes the first comprehensive regulation of donor-
advised funds, and it directly affects scholarship funds with donor involvement. Community
foundations that have the following ... review the operations of these funds to
determine whether they will be considered donor-advised funds under the new law:
• Donor-advised scholarship funds
• Alumni group scholarship funds
• Memorial scholarship ... churches or other charities
Grants and distributions to individuals now prohibited
for donor-advised funds
Beginning at the start of the first tax year following the August 17, 2006, enactment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01090583.pdf
EFTA01104426Set 9
2006-07-2621p7,866w
Means, House of
Representatives
July 2006
TAX-EXEMPT
ORGANIZATIONS
Collecting More Data
on Donor-Advised
Funds and Supporting
Organizations Could
Help Address
Compliance
Challenges ... Could Help Address Compliance
Challenges
Why GAO Did This Study What GAO Found
Donor-advised funds and Donor-advised funds, supporting organizations, and private foundations
supporting organizations ... exempt charitable-giving vehicles. Donor-advised funds are
charitable-giving options that have separate accounts held by a public charity to receive contributions from
received attention from Congress
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104426.pdf
EFTA01104564Set 9
2011-12-057p5,354w
DAFs is in
play. For most of their history DAFs flew under the
Donor-Advised Funds radar, receiving little scrutiny from Congress or
By Ray D. Madoff Treasury. However ... private foundations.
In this article, Madoff argues that the current law
governing donor-advised funds provides too much In this article, I argue that while DAFs serve ... making transfers to a implicating the government in a "wink and nod"
donor-advised fund. system that encourages artifice over substance. That
Copyright 2011 Ray D. Madoff. practice leaves donors
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104564.pdf
EFTA01104571Set 9
2014-01-137p1,981w
Myths About Payout Rules for Donor-Advised Funds - Opinion - The Chronicle of Phil... Page 1 of 7
OPINION
January 13, 2014
5 Myths About Payout Rules for Donor
-Advised Funds ... Madoff
Donor-advised funds are in the process of taking over the charitable landscape.
While giving to most charities has remained largely flat in recent years, contributions
to donor-advised ... their money have been the primary recipients of benefits from the growth of
donor-advised funds, while charities and the people they serve are being starved of
resources.
Donors
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104571.pdf
COUNCIL on FOUNDATIONS
Is the Fund a Donor-Advised Fund?
The flowchart on the following pages is designed to help community foundations determine
which funds should be classified as donor ... Pension Protection Act of 2006.
For more information about the definition of a donor-advised fund, see the document entitled
"Definition of a Donor-Advised Fund."
Summary
A fund ... only a donor-advised fund if:
• A donor or person appointed or designated by the donor has, or reasonably expects to
have, advisory privileges with respect to distributions or investments
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598164.pdf
EFTA00607665Set 9
2006-08-171p364w
COUNCIL on FOUNDATIONS
Reporting for Organizations that Hold Donor-Advised Funds
Effective Date: New Form 990 reporting is effective for taxable years ending after August 17,
2006. New Form ... recognition of
exempt status after August 17, 2006.
If our organization holds donor-advised funds, what information must we now provide on
Form 990?
A sponsoring organization, such ... community foundation, must now disclose the:
(1) Number of donor-advised funds owned;
(2) Aggregate value of assets held in donor-advised funds at the end of the tax year
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607665.pdf
EFTA00598316Set 9
2011-07-281p681w
Master Tax Guide (2011), 610. Donor Advised Funds
A charitable organization under Code Sec. 501(c)(3) (other than a private foundation) may establish a donor advised
fund which ... donor may be entitled to a charitable deduction for
contributions to a donor advised fund ( ¶1061), but only if the sponsoring organization legally owns and controls the
contributions. For this ... purpose, a donor advised fund does not include any fund that only makes distributions to a
single identified organization or governmental entity, or a fund that allows the donor
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598316.pdf
EFTA00598243Set 9
2008-07-3118p7,762w
DONOR-ADVISED FUNDS GUIDE SHEET EXPLANATION
July 31, 2008
PURPOSE
This Guide Sheet Explanation is designed to assist in the completion of the Donor-
Advised Funds Guide Sheet. It contains ... parts: a background part that explains the
history and taxation regime applicable to donor-advised funds and an explanation part
keyed to the donor-advised funds guide sheet.
BACKGROUND
Donor ... Pension Protection Act of
2006 (Pub. L. No. 109-208), the term "donor-advised fund" was not defined in the Code
or Regulations, but it was understood to include arrangements
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598243.pdf
EFTA00598155Set 9
2006-09-074p1,542w
COUNCIL on FOUNDATIONS
Definition of a Donor-Advised Fund
Revised — September 7, 2006
The Pension Protection Act of 2006 includes the first comprehensive regulation of donor-
advised funds. These ... that hold assets in such funds. However, a provision
barring the payment from donor-advised funds of grants, compensation and similar
payments to donors, advisors, and persons related to them ... which occurred on August 17, 2006. Understanding the
definition of what is a donor-advised fund also is important to the implementation of the
bill's charitable IRA rollover provision
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598155.pdf
EFTA00584409Set 9
10p2,845w
only a gates operation. No outside
involvement. Etc.
-Contribution Flexibility:
The GA Donor Advised Fund would accept and hold a wide array of
assets.
-Investment Choice and True Independence ... foundation allows unique giving structures. ( too
many details for this memo)
The GA Donor Advised Fund would be specifically designed to enhance
opportunities for ,initially, only very large giving. ( Bill ... charitable purposes, managed by the country's top investment
professionals. The GA Donor Advised Fund would let them structure
their giving over time, enabling them to leverage the impact
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584409.pdf