Comment from Bay Area Community Foundation
Bay Area Community FoundationOpposeAdvocacy
Summary: The Bay Area Community Foundation, a public charity, opposes the proposed regulations because they are overly broad, create unnecessary compliance costs, and lack evidence of widespread abuse. They specifically argue against the inclusion of personal investment advisors as donor advisors, express concern over the potential misclassification of advisory committees, and request a more favorable scholarship fund exception and a delayed effective date.
This comment letter is written on behalf of the Bay Area Community Foundation (Bay City, Michigan) in response to Notice of Rulemaking (REG-142338-07) regarding "Taxes on Taxable Distributions from Donor Advised Funds under Section 4966."
This letter discusses our issues and concerns as a community foundation that holds DAFs and other charitable funds that would have negative, and we believe unintended, consequences if made final in the current form. In particular, we are concerned about the:
* Overly broad definition of donor advised fund,
* Economic impact of the proposed regulations on sponsoring organizations,
* Scope of the scholarship fund exception, and
* Effective date.
These comments are detailed in the attached comment letter.