Proposed Regulations Regarding Taxes on Taxable Distributions From Donor-Advised Funds
On November 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations under section 4966 of the Internal Revenue Code of 1986, as amended (the “Code”), regarding excise taxes on taxable distributions made by a sponsoring organization from a donor-advised fund (a “DAF”), and on the agreement of certain fund managers to the making of such distributions (the “Proposed Regulations”). The Proposed Regulations propose a portion of the long-awaited guidance concerning amendments to the Code related to DAFs, which were enacted in the Pension Protection Act of 2006 (the “PPA”). The preamble to the Proposed Regulations also requests comments responding to questions raised by Treasury and the IRS.
The Proposed Regulations can be found here.