John — thank you for elaborating. Very helpful! I want to make sure I’m synthesizing your point correctly and applying it in the right framework.
My understanding is that, from an IRS perspective, a supporting organization’s transfer of funds to its parent institution is not a charitable contribution in the traditional sense, since the organization exists solely to carry out the institution’s exempt purpose and the transfer would not be deductible as a gift.
Where I’m trying to confirm alignment is on the counting and classification side under CASE. In a proceeds-based scenario where individual purchasers are not making defined charitable gifts and funds are transferred in aggregate, my reading of CASE 5.1.2 is that institutions should classify the revenue based on the legal entity from which the payments are received—meaning attribution at the supporting organization level rather than to individuals.
Does that reflect your understanding as well, assuming we’re separating tax treatment from CASE counting guidance?
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Gretchen Armentrout
James Madison University
housergh@jmu.edu
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Original Message:
Sent: 01-21-2026 12:26 PM
From: John Taylor
Subject: Soft/Recognition Credit Best Practice Question
Here's the statement from CASE on page 46. Please note that this isn't a change. Similar language goes back several editions - maybe to the 1980s, although my books are in the US and I am not so I cannot check!
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:
Sent: 1/21/2026 1:13:00 PM
From: John Taylor
Subject: RE: Soft/Recognition Credit Best Practice Question
Yes. Even if.
A supporting organization's donations should be counted in your fundraising totals as gifts are made TO that organization. Not FROM that organization. The same thing holds true for all your affiliated entities, including foundations and athletic associations. This is outlined in the CASE Standards.
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:
Sent: 1/21/2026 1:07:00 PM
From: Gretchen Armentrout
Subject: RE: Soft/Recognition Credit Best Practice Question
John - even if the Alumni Association is a separate 501(c)3?
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Gretchen Armentrout
James Madison University
housergh@jmu.edu
Original Message:
Sent: 01-21-2026 11:58 AM
From: John Taylor
Subject: Soft/Recognition Credit Best Practice Question
I agree with Isaac.
Furthermore, if the Alumni Association is a supporting organization of JMU, they cannot make gifts to you, as that is akin to making a gift to yourself. So, the "proceeds to benefit" avenue does not apply here for counting purposes.
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:
Sent: 1/21/2026 12:55:00 PM
From: Isaac Shalev
Subject: RE: Soft/Recognition Credit Best Practice Question
I would advise against any kind of crediting for this transaction. To me this is analogous to purchasing logo apparel at the campus store.
Thank you,
Isaac Shalev
Data Strategy Expert
Sage70, Inc.
(917) 859-0151
isaac@sage70.com
Schedule a 30-minute consultation now:
Original Message:
Sent: 1/21/2026 12:19:00 PM
From: Gretchen Armentrout
Subject: Soft/Recognition Credit Best Practice Question
Good afternoon colleagues!
I'm seeking best-practice guidance on how others handle soft/recognition credit in a proceeds-based fundraising scenario.
Scenario:
-
An affiliated organization (our Alumni Association) plans to sell a branded item (a Lego Duke Dog) to constituents.
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Purchasers understand that a stated portion of the proceeds will ultimately be donated to our Foundation to support a fund (TBD).
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The Alumni Association will:
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Receive all payments from individuals
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Make a single contribution of proceeds to the Foundation
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Retain legal donor status and receive tax acknowledgement
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The Foundation will not receive individual payments or gift intent directly from purchasers.
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This differs from traditional quid-pro-quo items (e.g., calendars/posters) where the charitable portion is explicitly defined and receipted as a gift from the purchaser.
Question:
In this type of arrangement-where funds arrive as proceeds from sales and the affiliated organization is the legal donor-do you:
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Provide soft or recognition credit to individual purchasers for a prorated amount of the proceeds?
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If yes, what documentation or criteria do you require (e.g., purchaser acknowledgment language, defined charitable portion, receipting responsibility, donor intent)?
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If no, do you treat recognition exclusively at the organizational level given the absence of a direct charitable gift from the individual?
Thank you in advance for sharing your practices and rationale.
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Gretchen Armentrout
Director, Gifts & Records
James Madison University
housergh@jmu.edu
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