The Pension Protection Act of 2006 (PPA), which so radically redefined the rules for supporting organizations, also transformed the rules for donor-advised funds (DAFs). The PPA for the first time accords DAFs express recognition in the Internal Revenue Code, a tribute to the recent rapid success of DAFs as well as the charities and commercial firms that sponsor them. But DAFs are given this recognition merely so they can be subjected to new taxes and restrictions — and the act imposes more
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