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  • 1.  Event Invitation - Including DAF/PF language

    Posted 04-08-2026 09:17 AM

    Hello!

    We have several key events which include table sponsorships at various levels.  Upon review, it seems that events team was accepting DAFs/PFs with benefits and unbeknownst to them, were bifurcating the funds as well.  In efforts to bring our org into compliance, I'm wondering if anyone has a sample disclosure language used on invitations/collateral about DAFs/PFs must be fully charitable and attendance/benefits are declined.  Any samples where this is printed on invitations are greatly appreciated. 

    Thank you!

    Michele



    ------------------------------
    Michele Hicks
    MD Anderson Cancer Center
    MMHicks1@mdanderson.org
    ------------------------------


  • 2.  RE: Event Invitation - Including DAF/PF language

    Posted 04-09-2026 10:36 AM

    Hi Michele, I do not have examples to share, but we are considering adding similar wording to our auction event invites among others. I am excited to see if anyone has examples to share and/or as we draft ours down the road, I would be happy to share with you then. 


    Steph 



    ------------------------------
    Stephanie Toms
    Florida Gulf Coast University Foundation, Inc.
    stoms@fgcu.edu
    ------------------------------



  • 3.  RE: Event Invitation - Including DAF/PF language

    Posted 04-09-2026 11:21 AM
    The statement must be in your own words and fit your culture and constituency. That said, the following is something I have offered. I also have a snappier version that's best for small community organizations where you pretty much know everybody.

    "A quick note: Under IRS rules, donor-advised funds, private foundations, and IRA qualified charitable distributions may be used only for the fully tax-deductible portion of a gift and cannot be applied to any benefits (such as event tickets, meals, or sponsorship benefits). These gifts also cannot be split to cover both the charitable and benefit portions."

    Snappier version:

    "A quick heads-up from our friends at the IRS: gifts from donor-advised funds, private foundations, or IRA qualified charitable distributions can be only used for the fully deductible portion of your support and may not be used for any associated benefits-or split to cover both portions."

    John


    John H. Taylor, Principal
    John H. Taylor Consulting, LLC
    2604 Sevier Street
    Durham, NC     27705

    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987





    Original Message


  • 4.  RE: Event Invitation - Including DAF/PF language

    Posted 04-09-2026 11:33 AM

    John, this is great. Thanks for sharing. And, I agree, we need to develop a version that best fits our individual constituencies. But, super helpful to have a place to start. 

    Steph 



    ------------------------------
    Stephanie Toms
    Florida Gulf Coast University Foundation, Inc.
    stoms@fgcu.edu
    ------------------------------

    Original Message


  • 5.  RE: Event Invitation - Including DAF/PF language

    Posted 06-03-2026 07:42 AM

    Hi John, 

    I totally missed your response here.  I thank you for that. I know IRS is very clear about bifurcation with DAFs.  I'm not finding the same literature about Private Foundations.  I've always operated under the advisement that PFs are treated like DAFs (I could have been misguided), but It seems that self-dealing would only come into play where the PF paid for the entire sponsorship amount.  However, a PF can pay for the charitable portion and the benefits can be paid separately by the event attendee.  Am I interpreting this correctly? 

    Thank you, 

    Michele



    ------------------------------
    Michele Hicks
    MD Anderson Cancer Center
    MMHicks1@mdanderson.org
    ------------------------------

    Original Message


  • 6.  RE: Event Invitation - Including DAF/PF language

    Posted 06-03-2026 08:45 AM
    I do not profess to be an expert in this area. I've not personally been associated with a private foundation. I am, therefore, attaching three reference documents that might be useful to you and suggest that your attorney use them to determine an appropriate course of action for your organization.

    John

    John H. Taylor, Principal
    John H. Taylor Consulting, LLC
    2604 Sevier Street
    Durham, NC     27705

    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987





    Attachment(s)

    pdf
    Private Foundations Tip Sheet - TNC.pdf   288 KB 1 version
    pdf
    2012 Family Foundation Talking Points.pdf   161 KB 1 version
    pdf
    Self-Dealing.pdf   268 KB 1 version
    Original Message


  • 7.  RE: Event Invitation - Including DAF/PF language

    Posted 06-03-2026 09:36 AM
    Michele, the rules against self-dealing originate with private foundations, in IRC 4941. Those rules say that self-dealing between a PF and a disqualified person (eg board member) is prohibited. In private letter rulings, the IRS established that bifurcation is considered self-dealing because it does confer an excess benefit on the disqualified person. This is prohibited for Private Foundations. 

    The issue that then arose was whether the same applies to DAFs, because DAFs are not PFs, they're public charities, and do not operate under the same self-dealing rules. In Notice 2017-73, the IRS says that they want to "prevent the use of DAFs to circumvent the excise tax rules applicable to private foundations under Chapter 42 of the Code." They therefore extend the PF restriction on bifurcation to DAFs.

    In other words, even though it seems like there is less material on bifurcation re PFs, that's actually source of the regulation, and it gets extended to DAFs, too. 


    Thank you,
    Isaac Shalev
    Data Strategy Expert
    Sage70, Inc.
    (917) 859-0151
    isaac@sage70.com

    Schedule a 30-minute consultation now:





    Original Message


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