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  • 1.  Valuing alternative investment - mutual fund-like vehicle with restriction on date of sale

    Posted 01-09-2024 11:53 AM

    Hello esteemed colleagues, 

    We'd love your expert opinion on our approach to the following scenario:

    A donor asked us to accept a sizable gift of an alternative investment vehicle - shares of a reinsurance fund - where the fund prohibits sales except for a few days each quarter (so 4 opportunities to sell per year). Our Gift Acceptance Committee evaluated the risk and approved accepting the gift. Our question for you is about gift valuation:

    We reviewed IRS pub 526, and it seems like we should value the gift based on the sale price data available for the date the shares came into the org's possession. This data is published, though it does not have a high/low; there is one value for the date in question, and the value changes slowly (so you'll see the same price for 4-8 days, and then a slight change). 

    We also had fun trying to force the transaction into The Raiser's Edge, which doesn't allow partial shares or ticker tape symbols in excess of 4 characters, even though this one has 5. But that was just mechanics to get it into the database, with copious documentation on the actual gift and valuation data & process.

    Do you have any recommendations or resources for strengthening our approach to valuing this gift? We are documenting our decisions and requesting final approval on our approach from our Gift Acceptance Committee as well.

    Many thanks in advance!

    The Gift Administration team at LPFCH



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    Faith Danforth
    The Lucile Packard Foundation for Children's Health
    Kelly.Dewees@lpfch.org
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  • 2.  RE: Valuing alternative investment - mutual fund-like vehicle with restriction on date of sale

    Posted 01-09-2024 12:19 PM
    I believe instruments like this will require the donor to obtain an appraisal and complete an 8283 to claim a deduction. I cannot say that for sure, but we had a few strange ones like this in my time where that was the case.

    I suggest your CFO contact the accountant for the donor to compare notes and obtain whatever documents they will use to value the donation for tax purposes (that is not your responsibility). Then, use whatever value they plan to use with that supporting documentation.

    In RE treat this as a gift-in-kind.

    John

    John H. Taylor
    Principal
    John H. Taylor Consulting, LLC
    2604 Sevier St.
    Durham, NC   27705
    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987






  • 3.  RE: Valuing alternative investment - mutual fund-like vehicle with restriction on date of sale

    Posted 01-09-2024 02:35 PM
    The fund you're describing sounds like an interval fund - you can buy shares anytime, but there is no secondary market for the shares, you can't sell them to anyone. The daily valuation of the fund (its NAV) is the price at which people can buy shares, and it is determined by valuing the underlying assets of the fund. The work is done by a third-party pricing agent like Bloomberg, so it is quite appropriate to rely on it as your FMV. However, because an interval fund is not a publicly traded security according to Pub 562, the donation can't be reported in Section A of the 8283. It's Section B, and it will require an appraisal. 



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

    Schedule a 30-minute consultation now:






  • 4.  RE: Valuing alternative investment - mutual fund-like vehicle with restriction on date of sale

    Posted 01-09-2024 04:29 PM

    Thank you both so much, John and Isaac! Very interesting. I do believe this is an interval fund. Thank you!



    ------------------------------
    Faith Danforth
    The Lucile Packard Foundation for Children's Health
    Kelly.Dewees@lpfch.org
    ------------------------------