NGOsource Comment on IRS Notice 2017-73

As previously posted on our blog, the IRS recently issued Notice 2017-73, a “Request for Comments on Application of Excise Taxes With Respect to Donor Advised Funds in Certain Situations.” The IRS Notice primarily summarizes three new regulations that the IRS is proposing to introduce regarding the operation of DAFs by 501(c)(3) sponsoring organizations. NGOsource believes that one of these three proposed regulations could have a negative impact on the number of non-U.S. organizations that qualify as equivalent to U.S. public charities under the existing rules. In response, NGOsource submitted comments to the IRS on Monday, March 5, expressing why we feel that requiring grantee organizations (both domestic and abroad) to treat DAF donations as donations from the individual donor-advisor, rather than from the 501(c)(3) sponsoring organization, would be unduly burdensome on non-US charities, and could have negative consequences on international philanthropy.

Please see the attached PDF for the full comment.