Comment from Council of Michigan Foundations
Council of Michigan FoundationsOpposeAdvocacy
Summary: The Council of Michigan Foundations, a 501(c)(3) membership organization for philanthropy staff and trustees, opposes several aspects of the proposed regulations regarding excise taxes on taxable distributions from Donor Advised Funds (DAFs). They argue that the regulations treat public charity-owned DAFs less favorably than private foundations, create overly broad definitions for "donor-advisors" that include professional investment advisors, and introduce unnecessary uncertainty through "substance over form" provisions.
Please see the attached comments from the Council of Michigan Foundations in response to Notice of Rulemaking (REG–142338-07) regarding “Taxes on Taxable Distributions from Donor Advised Funds under Section 4966.” We appreciate the opportunity to share our thoughts and concerns regarding the proposed regulations and look forward to engaging with Treasury and the Internal Revenue Service in future discussions about these and other proposed rules you may be considering.