The comments from Paul Streckfus in his daily newsletter this morning highlight the ABA Tax Section comments on the proposed section 4966 DAF regulations. Many other organizations have submitted comments opposing various aspects of the proposals, but keep in mind who the drafters represent—mostly DAFs and those that depend on DAFs for their funding. On the other hand, many are rightfully concerned that the financial institutions have taken control over a huge proportion of charitable dollars that are funded, effectively, by the taxpayers. To those who like to “do their own research,” Farella's EO Radio Show episodes 62, 63, 64, and 65 describe the proposed regulations, without commentary, and the show notes link to the text of the proposed regulations.
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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