DISTRIBUTIONS FROM A DONOR ADVISED FUND TO A PRIVATE FOUNDATION

There is a widely held but misguided belief that a donor advised fund (“DAF”) is prohibited from making distributions to a private foundation. While the Pension Protection Act of 2006 imposed a myriad of restrictions on DAFs, it did not completely proscribe distributions from a DAF to a private foundation so long as the DAF sponsoring organization undertakes certain expenditure responsibility measures. Moreover, a DAF may make distributions to a private foundation even when a donor or donor advisor to the DAF is also a disqualified person with regard to the recipient private foundation.

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DAFs - Grants to Private Foundations CSH on letterhead NEW

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