I 

117TH CONGRESS 

2D SESSION H. R. 6595 

To amend the Internal Revenue Code of 1986 to modify rules relating to 

donor advised funds, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

FEBRUARY 3, 2022 

Ms. PINGREE (for herself, Mr. REED, Mr. KHANNA, and Ms. PORTER) introduced the following bill; which was referred to the Committee on Ways 

and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to modify 

rules relating to donor advised funds, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Accelerating Chari5 table Efforts Act’’ or the ‘‘ACE Act’’. 

6 SEC. 2. ADDITIONAL RESTRICTIONS ON DEDUCTIONS FOR 

7 CONTRIBUTIONS TO DONOR ADVISED FUNDS. 

8 (a) LIMITATION ON DEDUCTION.—Section 170(f) of 

9 the Internal Revenue Code of 1986 is amended by adding 

10 at the end the following new paragraph: 


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1 ‘‘(19) TIME FOR DEDUCTION OF CONTRIBU2 TIONS TO DONOR ADVISED FUNDS.— 

3 ‘‘(A) NONQUALIFIED DONOR ADVISED

4 FUNDS.— 

5 ‘‘(i) IN GENERAL.—In the case of a 

6 contribution to a donor advised fund (as 

7 defined in section 4966(d)(2)) which is not 

8 a qualified donor advised fund or a quali9 fied community foundation donor advised 

10 fund— 

11 ‘‘(I) in the case of any contribu12 tion of property other than cash, no 

13 deduction shall be allowed under this 

14 section unless the sponsoring organi15 zation sells such property for cash, 

16 ‘‘(II) no deduction shall be al17 lowed under this section for any con18 tribution before the taxable year that 

19 includes the date on which the spon20 soring organization makes a quali21 fying distribution of such contribution 

22 (or the proceeds from the sale of such 

23 contribution), and 


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1 ‘‘(III) the amount of the deduc2 tion shall be equal to the amount of 

3 the qualifying distribution. 

4 ‘‘(ii) QUALIFYING DISTRIBUTION.— 

5 For purposes of this subparagraph, the 

6 term ‘qualifying distribution’ means any 

7 distribution which is not a taxable distribu8 tion (as defined in section 4966(c), deter9 mined without regard to paragraph (2)(C) 

10 thereof). 

11 ‘‘(iii) ORDERING RULE.—For pur12 poses of this subparagraph, distributions 

13 shall be treated as made from contribu14 tions (and any earnings attributable there15 to) on a first-in, first-out basis. 

16 ‘‘(B) NONPUBLICLY TRADED ASSETS OF

17 QUALIFIED DONOR ADVISED FUNDS.— 

18 ‘‘(i) IN GENERAL.—In the case of a 

19 contribution of a non-publicly traded asset 

20 to a qualified donor advised fund or a 

21 qualified community foundation donor ad22 vised fund— 

23 ‘‘(I) no deduction shall be al24 lowed under this section for any tax25 able year before the taxable year that 


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1 includes the date on which the spon2 soring organization sells the asset, 

3 and 

4 ‘‘(II) the amount of the deduc5 tion allowed under subsection (a) shall 

6 not exceed the amount of gross pro7 ceeds received from such sale and 

8 credited to the account or fund identi9 fied with the taxpayer. 

10 ‘‘(ii) NON-PUBLICLY TRADED

11 ASSET.—For purposes of this subpara12 graph, the term ‘non-publicly traded asset’ 

13 means any asset for which (as of the date 

14 of the contribution) market quotations are 

15 not readily available on an established se16 curities market. 

17 ‘‘(C) CONTEMPORANEOUS WRITTEN AC18 KNOWLEDGEMENT.— 

19 ‘‘(i) IN GENERAL.—In the case of a 

20 contribution described in subparagraph (A) 

21 or (B), no deduction shall be allowed under 

22 subsection (a) for such contribution unless 

23 the taxpayer substantiates the contribution 

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1 soring organization that meets the require2 ments of clause (ii). 

3 ‘‘(ii) CONTENT OF ACKNOWLEDGE4 MENT.—An acknowledgement meets the 

5 requirements of this subparagraph if it in6 cludes the following information: 

7 ‘‘(I) The name of the donor. 

8 ‘‘(II) In the case of a contribu9 tion described in subparagraph (A)— 

10 ‘‘(aa) if such contribution is 

11 described in subparagraph 

12 (A)(i)(I), a certification that the 

13 asset was sold for cash and the 

14 amount of cash received in such 

15 sale, and 

16 ‘‘(bb) a certification that a 

17 qualifying distribution has been 

18 made from such contribution (or 

19 the proceeds from the sale of 

20 such contribution), an identifica21 tion of the amount of such quali22 fying distribution, and a state23 ment that the deductible amount 

24 may not exceed the amount of 

25 such qualifying distribution. 


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1 ‘‘(III) In the case of a contribu2 tion described in subparagraph (B), a 

3 certification that the asset was sold 

4 and the amount of the gross proceeds 

5 received from such sale and credited 

6 to the account or fund of the tax7 payer, together with a statement that 

8 the deductible amount may not exceed 

9 the amount of the gross proceeds re10 ceived from the sale of the asset and 

11 credited to the account or fund of the 

12 taxpayer. 

13 ‘‘(iii) CONTEMPORANEOUS.—For pur14 poses of clause (i), an acknowledgement 

15 shall be considered to be contemporaneous 

16 if the sponsoring organization provides it 

17 within 30 days of— 

18 ‘‘(I) in the case of a contribution 

19 described in subparagraph (A), the 

20 date of the qualifying distribution, 

21 and 

22 ‘‘(II) in the case of a contribu23 tion described in subparagraph (B), 

24 the date that the gross proceeds from 


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1 the sale of the asset are credited to 

2 the account or fund of the taxpayer. 

3 ‘‘(iv) INFORMATION TO SECRETARY.— 

4 A sponsoring organization required to pro5 vide an acknowledgement under this para6 graph shall provide to the Secretary the in7 formation contained in the acknowledge8 ment. Such information shall be provided 

9 at such time and in such manner as the 

10 Secretary may prescribe. 

11 ‘‘(D) QUALIFIED DONOR ADVISED FUND.— 

12 For purposes of this paragraph, the term 

13 ‘qualified donor advised fund’ means a donor 

14 advised fund (as defined in section 4966(d)(2)) 

15 established under an agreement that requires, 

16 for the duration of such fund, the termination 

17 of any advisory privilege with respect to any 

18 contribution (including any earnings thereon) 

19 made by any donor (or any person appointed or 

20 designated by a donor) before the last day of 

21 the 14th taxable year beginning after the tax22 able year in which the contribution was made. 

23 ‘‘(E) QUALIFIED COMMUNITY FOUNDATION

24 DONOR ADVISED FUND.—For purposes of this 

25 paragraph— 


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1 ‘‘(i) IN GENERAL.—The term ‘quali2 fied community foundation donor advised 

3 fund’ means a donor advised fund (as de4 fined in section 4966(d)(2)) which is 

5 owned or controlled by a qualified commu6 nity foundation and which meets one or 

7 more of the requirements of clauses (ii) or 

8 (iii). 

9 ‘‘(ii) MAXIMUM VALUE OF ADVISORY

10 PRIVILEGES.— 

11 ‘‘(I) IN GENERAL.—A donor ad12 vised fund meets the requirements of 

13 this clause if each individual who has 

14 advisory privileges with respect to 

15 such fund does not have advisory 

16 privileges with respect to 1 or more 

17 donor advised funds held by the quali18 fied community foundation with an 

19 aggregate value at any time after the 

20 date of the enactment of this para21 graph in excess of $1,000,000. 

22 ‘‘(II) INFLATION ADJUST23 MENT.—In the case of any taxable 

24 year beginning after 2021, the 

25 $1,000,000 amount in subclause (I) 


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1 shall be increased by an amount equal 

2 to such dollar amount multiplied by 

3 the cost-of-living adjustment deter4 mined under section 1(f)(3) for the 

5 calendar year in which the taxable 

6 year begins, determined by sub7 stituting in subparagraph (A)(ii) 

8 thereof ‘calendar year 2020’ for ‘cal9 endar year 2016’. If any amount as 

10 adjusted under the preceding sentence 

11 is not a multiple of $10,000, such dol12 lar amount shall be rounded to the 

13 next lowest multiple of $10,000. 

14 ‘‘(iii) MINIMUM PAYOUT.—A donor 

15 advised fund meets the requirements of 

16 this paragraph if the fund is established 

17 under an agreement that requires that the 

18 fund make qualifying distributions (as de19 fined in subparagraph (A)(ii)) each cal20 endar year in an amount not less than 5 

21 percent of the value of the fund (deter22 mined as of the last day of the preceding 

23 calendar year). 


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1 ‘‘(iv) QUALIFIED COMMUNITY FOUN2 DATION.—The term ‘qualified community 

3 foundation’ means an organization— 

4 ‘‘(I) which is described in section 

5 501(c)(3), 

6 ‘‘(II) which is organized and op7 erated for the purpose of under8 standing and serving the needs of a 

9 particular geographic community that 

10 is no larger than 4 States by engaging 

11 donors and pooling donations to cre12 ate charitable funds in direct further13 ance of those needs, and 

14 ‘‘(III) which holds substantial as15 sets (but in no case less than 25 per16 cent of the organization’s total assets) 

17 outside of donor advised funds. 

18 ‘‘(v) SPONSORING ORGANIZATION.— 

19 The term ‘sponsoring organization’ has the 

20 meaning given such term under section 

21 4966(d)(1).’’. 

22 (b) OTHER REQUIREMENTS FOR QUALIFIED DONOR

23 ADVISED FUNDS.—Section 170(f)(18) of the Internal 

24 Revenue Code of 1986 is amended by striking ‘‘and’’ at 

25 the end of subparagraph (A)(ii), by striking the period at 


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1 the end of subparagraph (B) and inserting ‘‘, and’’, and 

2 by adding at the end the following new subparagraph: 

3 ‘‘(C) in the case of a contribution to a 

4 qualified donor advised fund (as defined in 

5 paragraph (19)(D)), the taxpayer identifies for 

6 the sponsoring organization a preferred organi7 zation for the purposes of making distributions 

8 of so much of the amount contributed (and any 

9 earnings attributable thereto) as has not been 

10 distributed before the end of the last day of the 

11 14th taxable year beginning after the taxable 

12 year in which the contribution was made.’’. 

13 (c) EFFECTIVE DATE.—The amendments made by 

14 this section shall apply to contributions made after the 

15 date of the enactment of this Act. 

16 SEC. 3. FAILURE OF DONOR ADVISED FUNDS TO DIS17 TRIBUTE CONTRIBUTIONS. 

18 (a) IN GENERAL.—Subchapter G of chapter 42 of the 

19 Internal Revenue Code of 1986 is amended by adding at 

20 the end the following new section: 

21 ‘‘SEC. 4967A. FAILURE OF DONOR ADVISED FUNDS TO DIS22 TRIBUTE CONTRIBUTIONS. 

23 ‘‘(a) IN GENERAL.—In the case of a contribution 

24 which is held in a donor advised fund (other than a quali25 fied community foundation donor advised fund), there is 


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1 hereby imposed a tax equal to 50 percent of so much of 

2 the portion of such contribution (and any earnings attrib3 utable thereto) as has not been distributed by the spon4 soring organization in a qualifying distribution before the 

5 last day of the sixth month following the last day of the 

6 applicable taxable year with respect to such contribution. 

7 The tax imposed by this subsection shall be paid by such 

8 sponsoring organization. 

9 ‘‘(b) APPLICABLE TAXABLE YEAR.—For purposes of 

10 this section, the term ‘applicable taxable year’ means— 

11 ‘‘(1) in the case of a contribution to a qualified 

12 donor advised fund, the 14th taxable year beginning 

13 after the taxable year in which the contribution was 

14 made, and 

15 ‘‘(2) in the case of a contribution to any other 

16 donor advised fund (other than a qualified commu17 nity foundation donor advised fund), the 49th tax18 able year beginning after the taxable year in which 

19 the contribution was made. 

20 ‘‘(c) DEFINITIONS AND OTHER RULES.— 

21 ‘‘(1) QUALIFIED DONOR ADVISED FUND.—The 

22 term ‘qualified donor advised fund’ has the meaning 

23 given such term under section 170(f)(19)(D). 

24 ‘‘(2) QUALIFIED COMMUNITY FOUNDATION

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1 munity foundation donor advised fund’ has the 

2 meaning given such term under section 

3 170(f)(19)(E). 

4 ‘‘(3) QUALIFYING DISTRIBUTION.—The term 

5 ‘qualifying distribution’ has the meaning given such 

6 term under section 170(f)(19)(A)(ii). 

7 ‘‘(4) ORDERING RULE.—Rules similar to the 

8 rules of section 170(f)(19)(A)(iii) shall apply for 

9 purposes of this section.’’. 

10 (b) CONFORMING AMENDMENT.—The table of sec11 tions for subchapter G of chapter 42 of such Code is 

12 amended by adding at the end the following new item: 

‘‘Sec. 4967A. Failure of donor advised funds to distribute contributions.’’. 

13 (c) EFFECTIVE DATE.—The amendments made by 

14 this section shall apply to contributions made after the 

15 date of the enactment of this Act. 

16 SEC. 4. TREATMENT OF PRIVATE FOUNDATION ADMINIS17 TRATIVE EXPENSES PAID TO DISQUALIFIED 

18 PERSONS. 

19 (a) IN GENERAL.—Section 4942(g) of the Internal 

20 Revenue Code of 1986 is amended by adding at the end 

21 the following new paragraph: 

22 ‘‘(5) DISALLOWANCE OF ADMINISTRATIVE EX23 PENSES PAID TO DISQUALIFIED PERSONS.— 

24 ‘‘(A) IN GENERAL.—For purposes of para25 graph (1)(A), administrative expenses paid to 


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1 any person described in subparagraph (B) shall 

2 not be treated as a qualifying distribution. 

3 ‘‘(B) PERSON DESCRIBED.—A person is 

4 described in this subparagraph if such person is 

5 a disqualified person (as defined in section 

6 4946(a)(1)) with respect to the private founda7 tion, other than a foundation manager (as de8 fined in section 4946(b)(1)) of such private 

9 foundation who is not a member of the family 

10 (as defined in section 4946(d)) of any indi11 vidual described in subparagraph (A) or (C) of 

12 section 4946(a)(1).’’. 

13 (b) EFFECTIVE DATE.—The amendment made by 

14 this section shall apply to taxable years beginning after 

15 December 31, 2021. 

16 SEC. 5. TREATMENT OF DISTRIBUTIONS TO DONOR AD17 VISED FUNDS FROM PRIVATE FOUNDATIONS. 

18 (a) PROHIBITION ON TREATMENT AS QUALIFYING

19 DISTRIBUTIONS.— 

20 (1) IN GENERAL.—Section 4942(g)(1)(A) of the 

21 Internal Revenue Code of 1986 is amended by strik22 ing ‘‘paragraph (3), or’’ and inserting ‘‘paragraph 

23 (3), or (iii) a sponsoring organization (as defined in 

24 section 4966(d)(1)) if such contribution will be held 

25 in a donor advised fund (as defined in section 


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1 4966(d)(2)), except as provided in paragraph (3), 

2 or’’. 

3 (2) CONFORMING AMENDMENT.—Section 

4 4942(g)(3) is amended by striking ‘‘(i) or (ii)’’ and 

5 inserting ‘‘(i), (ii), or (iii)’’. 

6 (b) REPORTING.—Section 6033(c) of the Internal 

7 Revenue Code of 1986 is amended— 

8 (1) by redesignating paragraphs (1) and (2) as 

9 paragraphs (2) and (3), respectively, 

10 (2) by inserting before paragraph (2) (as redes11 ignated) the following new paragraph: 

12 ‘‘(1) the private foundation shall include in its 

13 annual return under this section information on— 

14 ‘‘(A) the amount of any contribution to a 

15 sponsoring organization (as defined in section 

16 4966(d)(1)) which will be held in a donor ad17 vised fund (as defined in section 4966(d)(2)), 

18 ‘‘(B) the sponsoring organization to which 

19 such contribution was made, and 

20 ‘‘(C) the donation advice given to such or21 ganization (if any),’’, and 

22 (3) in the matter following paragraph (3) (as 

23 redesignated) by striking ‘‘paragraph (1)’’ and in24 serting ‘‘paragraph (2)’’. 

25 (c) EFFECTIVE DATES.— 


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1 (1) PROHIBITION.—The amendment made by 

2 subsection (a) shall apply to distributions made after 

3 December 31, 2021. 

4 (2) REPORTING.—The amendments made by 

5 subsection (b) shall apply to returns required to be 

6 filed after December 31, 2021. 

7 SEC. 6. TREATMENT OF CONTRIBUTIONS FROM DONOR AD8 VISED FUNDS FOR PURPOSES OF DETER9 MINING PUBLIC SUPPORT. 

10 (a) PRIVATE FOUNDATIONS.—Section 509 of the In11 ternal Revenue Code of 1986 is amended by adding at the 

12 end the following new subsection: 

13 ‘‘(g) SPECIAL RULES FOR SUPPORT FROM DONOR

14 ADVISED FUNDS.— 

15 ‘‘(1) IN GENERAL.—For purposes of subsection 

16 (a)(2), except as otherwise provided in this sub17 section, all amounts received from sponsoring orga18 nizations (as defined in section 4966(d)(1))— 

19 ‘‘(A) shall not be treated as support re20 ceived from an organization described in section 

21 170(b)(1)(A), and 

22 ‘‘(B) shall be treated as support received 

23 from one person. 

24 ‘‘(2) EXCEPTION WHERE DONOR IDENTIFIED.— 

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1 tion which is provided from funds which are identi2 fied with a donor to a donor advised fund (as de3 fined in section 4966(d)(2)) and the sponsoring or4 ganization identifies such donor, such support shall 

5 be treated as provided by such donor. 

6 ‘‘(3) EXCEPTION FOR AMOUNTS NOT CONTRIB7 UTED FROM DONOR ADVISED FUNDS.—Paragraph 

8 (1) shall not apply to any amount if the sponsoring 

9 organization specifies that— 

10 ‘‘(A) the amount is not a distribution from 

11 a donor advised fund (as so defined), and 

12 ‘‘(B) no donor (or any person appointed or 

13 designated by such donor) had advisory privi14 leges with respect to the provision of the sup15 port.’’. 

16 (b) DETERMINATION OF CONTRIBUTION LIMITA17 TIONS.—Section 170(b)(1)(A) of such Code is amended by 

18 adding at the end the following: ‘‘For purposes of clause 

19 (vi), rules similar to the rules of section 509(g) shall 

20 apply.’’. 

21 (c) EFFECTIVE DATE.—The amendments made by 

22 this section shall apply to contributions made in taxable 

23 years beginning after the date of the enactment of this 

24 Act. 


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1 SEC. 7. EXEMPTION FROM TAX ON INVESTMENT INCOME 

2 FOR CERTAIN PRIVATE FOUNDATIONS MAK3 ING SIGNIFICANT QUALIFYING DISTRIBU4 TIONS. 

5 (a) IN GENERAL.—Section 4940 of the Internal Rev6 enue Code of 1986 is amended by adding at the end the 

7 following new subsection: 

8 ‘‘(e) EXEMPTION FOR FOUNDATIONS MAKING SIG9 NIFICANT QUALIFYING DISTRIBUTIONS.—No tax shall be 

10 imposed by this section for any taxable year on any private 

11 foundation if such private foundation makes qualifying 

12 distributions (as defined in section 4942(g)) during such 

13 taxable year in an amount that is not less than 7 percent 

14 of the excess of— 

15 ‘‘(1) the aggregate fair market value of all as16 sets of the foundation (other than those which are 

17 used (or held for use) directly in carrying out the 

18 foundation’s exempt purpose) determined as of the 

19 first date of the taxable year, over 

20 ‘‘(2) the acquisition indebtedness with respect 

21 to such assets (determined under section 

22 514(c)(1)).’’. 

23 (b) EFFECTIVE DATE.—The amendment made by 

24 this section shall apply to taxable years beginning after 

25 the date of the enactment of this Act. 


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1 SEC. 8. EXEMPTION FROM TAX ON INVESTMENT INCOME 

2 OF LIMITED-DURATION PRIVATE FOUNDA3 TIONS. 

4 (a) IN GENERAL.—Section 4940 of the Internal Rev5 enue Code of 1986, as amended by section 7, is amended 

6 by adding at the end the following new subsection: 

7 ‘‘(f) EXEMPTION FOR LIMITED-DURATION FOUNDA8 TIONS.— 

9 ‘‘(1) EXEMPTION.— 

10 ‘‘(A) IN GENERAL.—No tax shall be im11 posed by subsection (a) on any private founda12 tion if such private foundation meets the re13 quirements of subparagraph (B). 

14 ‘‘(B) REQUIREMENTS.—A private founda15 tion meets the requirements of this subpara16 graph if, at the time of its establishment and 

17 at all times thereafter— 

18 ‘‘(i) such private foundation has a du19 ration specified in its governing documents 

20 of not more than 25 years, and 

21 ‘‘(ii) such private foundation makes 

22 no distributions to disqualified private 

23 foundations. 

24 ‘‘(C) DISQUALIFIED PRIVATE FOUNDA25 TION.—For purposes of this subsection, the 

26 term disqualified private foundation means, 


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1 with respect to the private foundation described 

2 in subparagraph (B), another private founda3 tion with respect to which there is a disqualified 

4 person who is also a disqualified person with re5 spect to such private foundation described in 

6 subparagraph (B). 

7 ‘‘(2) RECAPTURE TAX.— 

8 ‘‘(A) IN GENERAL.—If— 

9 ‘‘(i) no tax is imposed under sub10 section (a) on a private foundation by rea11 son of paragraph (1), and 

12 ‘‘(ii) such private foundation— 

13 ‘‘(I) fails to meet the require14 ments of paragraph (1)(B) in any 

15 subsequent taxable year, 

16 ‘‘(II) has a duration of more 

17 than 25 years, or 

18 ‘‘(III) makes a distribution to a 

19 disqualified private foundation, 

20 a tax shall be imposed on such foundation 

21 in the amount determined under subpara22 graph (B) for the first taxable year in 

23 which such private foundation is described 

24 in clause (ii). 


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1 ‘‘(B) AMOUNT OF TAX.—The amount of 

2 tax determined under this subparagraph is the 

3 aggregate amount of taxes which would have 

4 been imposed on such private foundation for all 

5 taxable years before the first taxable year in 

6 which such foundation was described in sub7 paragraph (A)(ii) if paragraph (1) had not ap8 plied.’’. 

9 (b) EFFECTIVE DATE.—The amendment made by 

10 this section shall apply to taxable years beginning after 

11 the date of the enactment of this Act. 

Æ 


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