Comment from Marin Community Foundation
Marin Community FoundationOpposeAdvocacy
Summary: The Marin Community Foundation opposes the proposed regulations because they would create significant operational burdens and negative impacts on their personal investment advisor program. They specifically argue against the expanded definition of "donor advisors" to include personal investment advisors and request a transition period to avoid automatic excess benefit transactions.
This comment letter is written on behalf of Marin Community Foundation (“MCF”) in response to Notice of Rulemaking (REG–142338-07) regarding “Taxes on Taxable Distributions from Donor Advised Funds under Section 4966.” This letter discusses issues and concerns, raised by MCF, which is a sponsoring organization with various DAF and other programs. Below is a summary of the issues and concerns provided in this comment letter response: Default treatment of certain “financial advisors” as “donor-advisors”; Economic impact of the proposed regulations, specifically, in enacting the
proposed regulations pertaining to personal financial advisors; and Effective date and transition period.