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IRC § 4966 – The purpose of a grant must advance the
public good, as donors receive a charitable tax deduction for their
contributions to a donor advised fund. A grant cannot be made that
would not be 100% tax deductible.
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Grants must be made to US-based public charities that are registered
as a 501(c)(3) or are government entities or religious organizations;
they must be in good standing with the IRS. Grants cannot be made to
private non-operating foundations or other types of charitable
organizations that are not considered 501(c)(3), as the tax treatment
for these organizations are different.
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IRC § 4967, Pension Protection Act (Pub. L. 109-280)
– A grant cannot result in more than incidental benefits for the donor
or their family. A grant cannot be made that would not be 100% tax
deductible.
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Grants cannot be made that would not otherwise be 100% tax deductible
or that would result in more than incidental benefit, including uses
such as paying for dues or membership fees; purchasing tickets to a
benefit or other event; paying the donor for time or services
provided; the purchase of goods at charitable auctions; or supporting
a scholarship for which the donor controls the selection process.
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IRC § 4967 (Interpretation) – Funds contributed to a
DAF are legally owned by Raymond James Charitable and therefore cannot
satisfy a personal commitment made by an individual to support a
charity.
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Grants may be used to satisfy a non-legally binding pledge or
commitment, but cannot be used to satisfy an enforceable, binding
pledge or financial obligation.
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US OFAC – Grants must comply with OFAC regulations,
which prohibit all dealings with blocked parties and embargoed
countries.
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Grants may not be issued to parties that are blocked or that reside in
an embargoed country. Raymond James Charitable only allows grants to
be made to US-based charities.
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