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‘‘(ii) the sponsoring organization does 
not exercise expenditure responsibility with 
respect to such distribution in accordance 
with section 4945(h). 
‘‘(2) EXCEPTIONS.—Such term shall not in-
clude any distribution from a donor advised fund—
‘‘(A) to any organization described in sec-
tion 170(b)(1)(A) (other than a disqualified 
supporting organization), 
‘‘(B) to the sponsoring organization of 
such donor advised fund, or 
‘‘(C) to any other donor advised fund. 
‘‘(d) DEFINITIONS.—For purposes of this sub-
chapter—
‘‘(1) SPONSORING
ORGANIZATION.—The term 
‘sponsoring organization’ means any organization 
which—
‘‘(A) is described in section 170(c) (other 
than in paragraph (1) thereof, and without re-
gard to paragraph (2)(A) thereof), 
‘‘(B) is not a private foundation (as de-
fined in section 509(a)), and 
‘‘(C) maintains 1 or more donor advised 
funds. 
‘‘(2) DONOR ADVISED FUND.—
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‘‘(A) IN GENERAL.—Except as provided in 
subparagraph (B) or (C), the term ‘donor ad-
vised fund’ means a fund or account—
‘‘(i) which is separately identified by 
reference to contributions of a donor or do-
nors, 
‘‘(ii) which is owned and controlled by 
a sponsoring organization, and 
‘‘(iii) with respect to which a donor 
(or any person appointed or designated by 
such donor) has, or reasonably expects to 
have, advisory privileges with respect to 
the distribution or investment of amounts 
held in such fund or account by reason of 
the donor’s status as a donor. 
‘‘(B) EXCEPTIONS.—The term ‘donor ad-
vised fund’ shall not include any fund or ac-
count—
‘‘(i) which makes distributions only to 
a single identified organization or govern-
mental entity, or 
‘‘(ii) with respect to which a person 
described in subparagraph (A)(iii) advises 
as to which individuals receive grants for
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travel, study, or other similar purposes, 
if—
‘‘(I) such person’s advisory privi-
leges are performed exclusively by 
such person in the person’s capacity 
as a member of a committee all of the 
members of which are appointed by 
the sponsoring organization, 
‘‘(II) no combination of persons 
described in subparagraph (A)(iii) (or 
persons related to such persons) con-
trol, directly or indirectly, such com-
mittee, and 
‘‘(III) all grants from such fund 
or account are awarded on an objec-
tive and nondiscriminatory basis pur-
suant to a procedure approved in ad-
vance by the board of directors of the 
sponsoring organization, and such 
procedure is designed to ensure that 
all such grants meet the requirements 
of paragraphs (1), (2), or (3) of sec-
tion 4945(g). 
‘‘(C) SECRETARIAL AUTHORITY.—The Sec-
retary may exempt a fund or account not de-
870
scribed in subparagraph (B) from treatment as 
a donor advised fund—
‘‘(i) if such fund or account is advised 
by a committee not directly or indirectly 
controlled by the donor or any person ap-
pointed or designated by the donor for the 
purpose of advising with respect to dis-
tributions from such fund (and any related 
parties), or 
‘‘(ii) if such fund benefits a single 
identified charitable purpose. 
‘‘(3) FUND MANAGER.—The term ‘fund man-
ager’ means, with respect to any sponsoring organi-
zation—
‘‘(A) an officer, director, or trustee of such 
sponsoring organization (or an individual hav-
ing powers or responsibilities similar to those of 
officers, directors, or trustees of the sponsoring 
organization), and 
‘‘(B) with respect to any act (or failure to 
act), the employees of the sponsoring organiza-
tion having authority or responsibility with re-
spect to such act (or failure to act). 
‘‘(4) DISQUALIFIED
SUPPORTING
ORGANIZA-
TION.—