Wealth Management. Distributions by Private Foundations and Donor Advised Funds: Procedures for Determining Recipient s Public Charity Status

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1 Wealth Management December 2007 ALBANY AMSTERDAM ATLANTA BOCA RATON BOSTON CHICAGO DALLAS DELAWARE DENVER FORT LAUDERDALE HOUSTON LAS VEGAS LOS ANGELES MIAMI NEW JERSEY NEW YORK ORANGE COUNTY ORLANDO PHILADELPHIA PHOENIX SACRAMENTO SILICON VALLEY TALLAHASSEE TAMPA TYSONS CORNER WASHINGTON, D.C. WEST PALM BEACH ZURICH Strategic Alliances with Independent Law Firms BRUSSELS LONDON MILAN ROME TOKYO Distributions by Private Foundations and Donor Advised Funds: Procedures for Determining Recipient s Public Charity Status The Pension Protection Act of 2006 (the PPA ) significantly revised the rules regarding whether grants made by a private foundation to certain types of public charities will constitute qualifying distributions for purposes of the foundation s minimum distribution requirements. It also created new definitions of taxable distributions, some of which apply to a donor advised fund ( DAF ), under which a distribution will be treated as a taxable distribution, potentially subject to a 20 percent excise tax. In both cases, the recipient s public charity status for income tax purposes is of primary importance in determining the applicable tax consequences. Accordingly, as the year-end approaches and grant decisions are made, both private foundations and DAFs should consider the following when determining the public charity status of a potential grant recipient. PUBLIC CHARITY CLASSIFICATIONS The Code generally divides public charities into two categories: 1. Organizations under 509(a)(1) or (2), which receive a substantial amount of public support to fund their operations, or 2. Organizations under 509(a)(3), which support certain publicly supported organizations ( supporting organizations ). Supporting organizations are further subdivided into Types based upon the relationship they have with their supported organizations: Type I: The supporting organization is operated, supervised or controlled by one or more publicly supported organizations. Type II: The supporting organization is supervised or controlled in connection with one or more publicly supported organizations. Type III: The supporting organization is operated in connection with one or more publicly supported organizations. Functionally Integrated Type III: A Type III supporting organization that is not required to make payments to its supported organizations since its activities relate to the performance of the functions and purposes of its supported organizations.

2 As discussed below, the classification of a grant recipient s public charity status can impact the tax consequences of distributions made to such an organization by a private foundation or DAF. RESTRICTIONS ON GRANTS TO SUPPORTING ORGANIZATIONS Despite the classification of supporting organizations as public charities, the Code, pursuant to changes made by the PPA, may now impose restrictions and/or excise taxes on distributions made from private foundations or DAFs to the following types of supporting organizations: Type III supporting organizations that are not functionally integrated; and Type I, Type II, and functionally integrated Type III supporting organizations if a disqualified person (in the case of a private foundation) or the donor, the donor advisor or any related party (in the case of a DAF) directly or indirectly controls such supporting organization or one of its supported organizations. An organization is deemed controlled by one or more disqualified persons with respect to a private foundation, or by the donor, donor advisor or a related person with respect to a DAF, if any of such persons may, by aggregating their votes or positions of authority, require the supporting or supported organization to make or to deny an expenditure, regardless of how the control is exercised (i.e., whether directly or indirectly). Distributions made to public charities that are controlled directly or indirectly by a private foundation or a DAF may be subject to restrictions and/or excise taxes. ADVERSE TAX CONSEQUENCES Private Foundations must be wary of making distributions made to 509(a)(1) or (a)(2) organizations controlled by the private foundation or disqualified persons; and 509(a)(3) supporting organizations controlled by the private foundation or disqualified person, or whose supported organization is so controlled. DAFs must be wary of making distributions to a 509(a)(3) supporting organization that is controlled by, or which supports an organization that is controlled by the DAF s donor, donor advisor or any related person. Distributions to the above described organizations ( non-qualifying distributions ) may result in the following adverse income tax consequences for private foundations and DAFs: Consequences to Private Foundations Minimum Distribution Requirement: Non-qualifying distributions will not count towards the satisfaction of a private foundation s annual minimum distribution requirement. Failure to make the minimum distributions could cause the private foundation to incur an excise tax on its undistributed income.

3 Taxable Expenditure: Certain non-qualifying distributions to supporting organizations will constitute taxable expenditures subject to excise tax, unless the private foundation exercises expenditure responsibility. Expenditure Responsibility: Expenditure responsibility requires a private foundation to take the following actions, in strict compliance with the applicable Treasury Regulations: See that the grant is spent solely for the purpose for which it was made, Obtain full and complete reports from the grantee on how the funds are spent, and Make full and detailed reports on the expenditures to IRS. Consequences to Donor Advised Funds Taxable Distributions: Non-qualifying distributions will be deemed taxable distributions, unless the DAF s sponsoring organization exercises expenditure responsibility (as described above). The Code imposes an excise tax on each taxable distribution equal to: 20 percent of the distribution, charged to the DAF s sponsoring organization; and 5 percent of the distribution, charged to any fund manager that agreed to the distribution, knowing that it was a taxable distribution. GRANTEE REVIEW Eligible Public Charities Based on the above, private foundation and DAFs can make distributions that will count toward the minimum distribution requirement to the following public charities ( eligible public charities ) without incurring an excise tax or having to exercise expenditure responsibility: 509(a)(1) and (a)(2) organizations; provided, however, that for private foundations, the organization cannot be controlled by the foundation or a disqualified person. Type I, Type II and Functionally Integrated Type III 509(a)(3) supporting organizations that are not controlled by, and whose supported organizations are not controlled by, (1) in the case of a private foundation, the foundation itself or a disqualified person of the foundation, or, (2) in the case of a DAF, the a donor, a donor advisor or any related person thereto. Given the adverse tax consequences that may result from non-qualifying distributions to charities other than eligible public charities, private foundations and DAFs, as grantors, should take the following actions prior to making any distributions to a potential grantee (please see the decision tree that follows this article for a summary of these guidelines):

4 Review Procedures 1. Determine the Grantee s Public Charity Status A grantor must determine a potential grantee s public charity classification as either a 509 (a)(1), (2) or (3) organization. Pursuant to Notice , a grantor can make this determination by relying, in good faith, on either: A Determination Letter: The grantee's current IRS determination letter, if it recognizes the grantee s tax exempt status and indicates the grantee's public charity classification; or The BMF: Information provided in the IRS Business Master File ( BMF ). To access the BMF, grantors should use one of the following procedures (see Issue , IRS Exempt Organization Newsletter (March 27, 2007)): 1. The grantor may download the BMF directly from the IRS website (updated monthly). Many users, however, have experienced difficulty using the file. 2. Alternatively, a grantor may use a third party service provider to obtain the BMF information. The service provider must furnish the grantor with a report that includes the following information: a) The grantee s name, Employer Identification Number, and public charity classification under 509(a)(1), (2), or (3); b) A statement that the information is from the most-currently available IRS update to the BMF, along with the IRS BMF revision date; and c) The date and time of the grantor's search. The grantor must retain the report in hard copy or electronic form. 2. If the Grantee is a Supporting Organization, Determine the Type For a grantee classified as a supporting organization, the grantor must determine whether the grantee is a Type I, Type II, Type III or Functionally Integrated Type III supporting organization. Since the BMF does not supply this information, Notice provides grantors with two methods for making this determination: Opinion of Counsel: A grantor may rely on a reasoned, written opinion from the counsel of either the grantor or the grantee stating the grantee s type of supporting organization. Grantee s Written Representation: A grantor may rely, in good faith, on a written representation signed by a grantee s officer, director or trustee specifying the type of supporting organization, provided that the following requirements are met:

5 The documentation provided by the grantee is consistent with its representations; The grantor verifies that the grantee is listed in Publication 78, Cumulative List of Organizations described in 170(c) or obtains a copy of the grantee s current IRS determination letter; and If the grantee is a Type I or Type II supporting organization: The representation describes how the grantee's officers, directors, or trustees are selected and references any provisions in governing documents that establish a Type I or a Type II relationship between the grantee and its supported organization(s); and The grantor collects and reviews copies of the grantee s governing documents (and, if relevant, of the supported organization(s)); or If the grantee is a Functionally Integrated Type III supporting organization: The representation identifies the supported organization(s) with which the grantee is functionally integrated; The grantor obtains and reviews copies of the grantee s (and, if relevant, the supported organizations ) governing documents and/or other documents as necessary to evidence the grantee s relationship to its supported organizations; and The grantor obtains and reviews a written representation signed by an officer, a director or a trustee of each identified supported organization describing the grantee s activities and confirming that, but for the grantee s activities relating to the performance of the functions and purposes of the supported organization, the supported organization would normally engage in those activities itself. 3. Determine Whether the Grantee is Controlled by the Private Foundation or DAF A private foundation or DAF must also determine whether it has direct or indirect control over the potential grantee, as follows: 509(a)(1) and (2) Organizations. Private foundations must review the management and voting power of a grant recipient classified as a 509(a)(1) or (a)(2) organization to determine whether the private foundation or any disqualified person controls the public charity. Supporting Organizations. In the case of a grantee classified as a supporting organization, both private foundations and DAFs should (1) review the management and voting power of the grantee itself and (2) obtain a list of the grantee's supported organizations in order to determine whether the supporting organization or any of the supported organizations are controlled by a disqualified person of the private foundation or by the donor, donor advisor or any related person of the DAF.

6 4. If the Grantee is an Eligible Public Charity, Make the Distribution Assuming all other applicable Code provisions are satisfied, if the private foundation or DAF has determined, in accordance with the above, that the grantee is an eligible public charity, it may make a distribution to the grantee without incurring an excise tax or having to exercise expenditure responsibility. ADDITIONAL RECOMMENDATIONS In light of the complexity imposed by the new rules, grantors and grantees may also wish to consider the following recommendations: Given the difficulty faced by users when accessing the BMF, grantors may want to engage a service provider to obtain the required public charity information and produce the necessary report. An example of such a service provider is GuideStar s Charity Check Service. In addition to the limitations imposed on grants from private foundations and DAFs, 509(a)(3) supporting organizations are not eligible for IRA charitable rollover distributions. Grant recipients currently classified as 509(a)(3) supporting organizations, particularly those that are not Functionally Integrated Type III organizations, may want to request a change in their classification status to a 509(a)(1) or 509(a)(2) public charity, if possible. In order to request a change in charity status, the organization must file a written request with the IRS, in accordance with the requirements of Rev. Proc , IRB 135.

7 Grants to Public Charities A Decision Tree for Private Foundations and Donor Advised Funds Is the grantee a 509(a)(1) or (a)(2) organization? Confirm either by (1) obtaining the grantee s IRS determination letter or (2) by accessing the IRS Business Master File ( BMF ), either directly or through a service provider. NO YES Is the grantee a 509(a)(3) supporting organization? Confirm with either (1) the grantee s IRS determination letter or (2) the BMF. YES Is the grantee a Type I, Type II or Functionally Integrated Type III supporting organization? Confirm with either the: A. Written Opinion of the Grantor s Counsel or the Grantee s Counsel; or B. Grantee s Written Representation: Signed by a grantee s officer/director/ trustee specifying the Type and meeting the following requirements: 1. The grantee s documentation is consistent with its representations; 2. The grantee is listed in Publication 78, Cumulative List of Organizations described in 170(c) or provides its current IRS determination letter; and 3. The grantor reviews copies of the grantee s (and, if relevant, the supported organizations ) governing and other documents to evidence the grantee s relationship to its supported organizations; and 4. For a Type I or Type II supporting organization, the representation describes the selection of grantee's officers/directors/ trustees and references governing documents that establish a Type I or Type II relationship; or 5. For a Functionally Integrated Type III supporting organization, (a) the representation identifies the supported organization(s) with which the grantee is functionally integrated; and (b) the grantor receives a written representation signed by an officer/ director/trustee of each identified supported organization evidencing the functionally integrated relationship. YES NO NO Is the grantee independent of (not controlled by) the private foundation / DAF? 509(a)(1) and (2) Organizations. A private foundation must determine whether it or any disqualified person controls the public charity. Supporting Organizations. Both private foundations and DAFs must determine whether the grantee or any of its supported organizations are controlled by a disqualified person of the private foundation or by the donor, donor advisor or any related person of the DAF. NO YES Eligible Public Charity: Distribution should count towards minimum distribution requirements and should not be subject to excise tax or expenditure responsibility, assuming all other Code requirements are met. Not an Eligible Public Charity: Distribution may be a nonqualifying distribution. Will not count towards minimum distribution requirements for private foundations and may qualify as a taxable distribution for DAFs. May be subject to excise tax, unless expenditure responsibility is exercised.

8 This GT Alert was written by Tracy Green Landauer, Jonathan Forster and Jennifer Smith. Questions about the content of this Alert can be directed to Ms. Landauer at Mr. Forster at Ms. Smith at or any member of our Wealth Management Practice Group in the GT offices listed below. Albany Amsterdam Atlanta Boca Raton Boston Chicago Dallas Delaware Denver Fort Lauderdale Houston Las Vegas Los Angeles Miami New Jersey New York Orange County Orlando Philadelphia Phoenix Sacramento Silicon Valley Tallahassee Tampa Tysons Corner Washington, D.C West Palm Beach Zurich This Greenberg Traurig Alert is issued for informational purposes only and is not intended to be construed or used as general legal advice. The hiring of a lawyer is an important decision. Before you decide, ask for written information about the lawyer s legal qualifications and experience. Greenberg Traurig is a trade name of Greenberg Traurig, LLP and Greenberg Traurig, P.A Greenberg Traurig, LLP. All rights reserved.

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