The Pension Protection Act of 2006 (PPA) mandated the Treasury to examine concerns regarding the operation of donor-advised funds (DAFs) and to investigate whether their use was supporting charitable purposes.1 In 2011, the Treasury concluded in a report (the Report) the DAF rules enacted as part of the PPA addressed abusive practices.2
Its three key findings removed any reservations about the intermediate term viability of DAFs. First, contributions to the DAF were deemed outside the donor’s control and treated as completed gifts to public charities notwithstanding the high rate of approval of donors’ recommendations.3 Second, the lag time between the time of contribution and actual dispersal of funds for a charitable purpose were no di...
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