879 
‘‘(C) a 35-percent controlled entity (as de-
fined in section 4958(f)(3) by substituting ‘per-
sons described in subparagraph (A) or (B) of 
section 4943(e)(2)’ for ‘persons described in 
subparagraph (A) or (B) of paragraph (1)’ in 
subparagraph (A)(i) thereof). 
‘‘(3) PRESENT
HOLDINGS.—For purposes of 
this subsection, rules similar to the rules of para-
graphs (4), (5), and (6) of subsection (c) shall apply 
to donor advised funds (as so defined), except that— 
‘‘(A) ‘the date of the enactment of this 
subsection’ shall be substituted for ‘May 26, 
1969’ each place it appears in paragraphs (4), 
(5), and (6), and 
‘‘(B) ‘January 1, 2007’ shall be sub-
stituted for ‘January 1, 1970’ in paragraph 
(4)(E).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 1234. TREATMENT OF CHARITABLE CONTRIBUTION 
DEDUCTIONS TO DONOR ADVISED FUNDS. 
(a) INCOME.—Section 170(f) (relating to disallow-
ance of deduction in certain cases and special rules), as 
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ccoleman on PROD1PC71 with BILLS
880 
amended by this Act, is amended by adding at the end 
the following new paragraph: 
‘‘(18) CONTRIBUTIONS
TO
DONOR
ADVISED 
FUNDS.—A deduction otherwise allowed under sub-
section (a) for any contribution to a donor advised 
fund (as defined in section 4966(d)(2)) shall only be 
allowed if— 
‘‘(A) the sponsoring organization (as de-
fined in section 4966(d)(1)) with respect to 
such donor advised fund is not— 
‘‘(i) described in paragraph (3), (4), 
or (5) of subsection (c), or 
‘‘(ii) a type III supporting organiza-
tion (as defined in section 4943(f)(5)(A)) 
which is not a functionally integrated type 
III supporting organization (as defined in 
section 4943(f)(5)(B)), and 
‘‘(B) the taxpayer obtains a contempora-
neous written acknowledgment (determined 
under rules similar to the rules of paragraph 
(8)(C)) from the sponsoring organization (as so 
defined) of such donor advised fund that such 
organization has exclusive legal control over the 
assets contributed.’’. 
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ccoleman on PROD1PC71 with BILLS
881 
(b) ESTATE.—Section 2055(e) is amended by adding 
at the end the following new paragraph: 
‘‘(5) CONTRIBUTIONS
TO
DONOR
ADVISED 
FUNDS.—A deduction otherwise allowed under sub-
section (a) for any contribution to a donor advised 
fund (as defined in section 4966(d)(2)) shall only be 
allowed if— 
‘‘(A) the sponsoring organization (as de-
fined in section 4966(d)(1)) with respect to 
such donor advised fund is not— 
‘‘(i) described in paragraph (3) or (4) 
of subsection (a), or 
‘‘(ii) a type III supporting organiza-
tion (as defined in section 4943(f)(5)(A)) 
which is not a functionally integrated type 
III supporting organization (as defined in 
section 4943(f)(5)(B)), and 
‘‘(B) the taxpayer obtains a contempora-
neous written acknowledgment (determined 
under rules similar to the rules of section 
170(f)(8)(C)) from the sponsoring organization 
(as so defined) of such donor advised fund that 
such organization has exclusive legal control 
over the assets contributed.’’. 
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ccoleman on PROD1PC71 with BILLS
882 
(c) GIFT.—Section 2522(c) is amended by adding at 
the end the following new paragraph: 
‘‘(5) CONTRIBUTIONS
TO
DONOR
ADVISED 
FUNDS.—A deduction otherwise allowed under sub-
section (a) for any contribution to a donor advised 
fund (as defined in section 4966(d)(2)) shall only be 
allowed if— 
‘‘(A) the sponsoring organization (as de-
fined in section 4966(d)(1)) with respect to 
such donor advised fund is not— 
‘‘(i) described in paragraph (3) or (4) 
of subsection (a), or 
‘‘(ii) a type III supporting organiza-
tion (as defined in section 4943(f)(5)(A)) 
which is not a functionally integrated type 
III supporting organization (as defined in 
section 4943(f)(5)(B)), and 
‘‘(B) the taxpayer obtains a contempora-
neous written acknowledgment (determined 
under rules similar to the rules of section 
170(f)(8)(C)) from the sponsoring organization 
(as so defined) of such donor advised fund that 
such organization has exclusive legal control 
over the assets contributed.’’. 
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ccoleman on PROD1PC71 with BILLS
883 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to contributions made after the 
date which is 180 days after the date of the enactment 
of this Act. 
SEC. 1235. RETURNS OF, AND APPLICATIONS FOR RECOGNI-
TION BY, SPONSORING ORGANIZATIONS. 
(a) MATTERS INCLUDED ON RETURNS.— 
(1) IN GENERAL.—Section 6033, as amended 
by this Act, is amended by redesignating subsection 
(k) as subsection (l) and by inserting after sub-
section (j) the following new subsection: 
‘‘(k) ADDITIONAL PROVISIONS RELATING TO SPON-
SORING ORGANIZATIONS.—Every organization described 
in section 4966(d)(1) shall, on the return required under 
subsection (a) for the taxable year— 
‘‘(1) list the total number of donor advised 
funds (as defined in section 4966(d)(2)) it owns at 
the end of such taxable year, 
‘‘(2) indicate the aggregate value of assets held 
in such funds at the end of such taxable year, and 
‘‘(3) indicate the aggregate contributions to and 
grants made from such funds during such taxable 
year.’’. 
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to returns filed for 
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