The ABA Tax Section has submitted 44 pages of mostly negative comments on the proposed section 4966 DAF regulations. They are accessible at americanbar.org. Today I’m reprinting the Executive Summary. The problem with most of the comments received to date is that they reflect the views of the DAF industry. Over the years members of the ABA’s Tax Section have admitted that they are primarily a trade association representing their clients. My sense is that most of the identified contributors to the ABA submission have clients who are DAF sponsors and hence tend to represent the DAF industry, which is reshaping the charitable sector. DAF opponents argue that unregulated DAFs and DAF sponsors are not serving the best interests of working charities. The hearing on the proposed DAF regulations is scheduled for May 6. ~Paul Streckfus, Editor, EO Tax Journal

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