The Tax Law of Charitable Giving. Bruce R. Hopkins

The Tax Law of Charitable Giving - Bruce R. Hopkins


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requirement, a supporting organization must distribute, for each of its years, to or for the use of one or more supported organizations amounts equaling or exceeding its annual distributable amount on or before the last day of the year involved. These supporting organizations are required to annually distribute an amount equal to the greater of 85 percent of adjusted net income or 3.5 percent of the fair market value of the supporting organization's non-exempt-use assets.479 This payout approach includes a form of set-aside.

      1 Private operating foundations.501 This type of private foundation is an organization that would be a standard private foundation but for the fact that most of its earnings and much of its assets are devoted directly to the conduct of its charitable activities.502

      2 Conduit foundations.503 This type of private foundation makes timely qualifying distributions (usually grants)504 that are treated as distributions out of corpus, in an amount equal in value to all contributions received in the year involved, whether as cash or property.505

      3 Common fund foundations.506 This type of private foundation pools contributions received in a common fund but allows donors to retain the right to designate annually the organizations to which the income


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