Comment from Sustainable Economies Law Center

Sustainable Economies Law CenterSupportAdvocacy
Summary: The Sustainable Economies Law Center supports the proposed regulations but argues they fail to address the "legal fiction" of donor control over Donor Advised Funds (DAFs). They recommend establishing specific criteria and a "facts and circumstances" test to ensure that DAF sponsors exercise meaningful ownership and control, suggesting that funds with high donor control should be taxed and regulated like private foundations.
Please see the attached file.

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