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‘‘Subchapter G—Donor Advised Funds
‘‘Sec. 4967. Taxes on sponsoring organizations of donor advised funds for failure
to meet distributions requirements.
‘‘Sec. 4968. Taxes on prohibited distributions.
‘‘Sec. 4969. Taxes on prohibited benefits.
‘‘SEC. 4967. TAXES ON SPONSORING ORGANIZATIONS OF
DONOR ADVISED FUNDS FOR FAILURE TO
MEET DISTRIBUTION REQUIREMENTS.
‘‘(a) INITIAL TAX.—There is hereby imposed on any
sponsoring organization a tax equal to 30 percent of each
of the following amounts:
‘‘(1) 
The 
organization 
level 
undistributed
amount of such sponsoring organization (other than
any organization subject to tax under section 4942)
for any taxable year which has not been distributed
before the first day of the second (or any succeeding)
taxable year following such taxable year (if such first
day falls within the taxable period).
‘‘(2) The fund level undistributed amount of any
donor advised fund of such sponsoring organization
for any taxable year which has not been distributed
before the 181st day of the first (or any succeeding)
taxable year following the applicable period (if such
181st day falls within the taxable period).
‘‘(3) The illiquid fund undistributed amount of
any illiquid asset donor advised fund of such spon-
soring organization for any taxable year which has
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not been distributed before the 181st day of the second
(or any succeeding) taxable year following such tax-
able year (if such 181st day falls within the taxable
period).
‘‘(b) ADDITIONAL TAX.—In any case in which an ini-
tial tax is imposed under subsection (a) on any amount,
if any portion of such amount remains undistributed at
the close of the taxable period, there is hereby imposed a
tax equal to 100 percent of the amount remaining undis-
tributed at such time.
‘‘(c) ORGANIZATION LEVEL UNDISTRIBUTED AMOUNT;
FUND LEVEL UNDISTRIBUTED AMOUNT; ILLIQUID FUND
UNDISTRIBUTED AMOUNT.—For purposes of this section—
‘‘(1) 
ORGANIZATION
LEVEL
UNDISTRIBUTED
AMOUNT.—The term ‘organization level undistributed
amount’ means, with respect to any sponsoring orga-
nization for any taxable year, the amount by which—
‘‘(A) the organization level distributable
amount for such taxable year, exceeds
‘‘(B) the qualifying distributions made dur-
ing such taxable year and designated for the
purpose of reducing such amount.
‘‘(2) FUND LEVEL UNDISTRIBUTED AMOUNT.—
The term ‘fund level undistributed amount’ means,
with respect to any donor advised fund of a spon-
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soring organization for any applicable period, the
amount by which—
‘‘(A) the fund level distributable amount for
such applicable period, exceeds
‘‘(B) the qualifying distributions made dur-
ing such applicable period and designated for the
purpose of reducing such amount.
‘‘(3) ILLIQUID FUND UNDISTRIBUTED AMOUNT.—
‘‘(A) IN GENERAL.—The term ‘illiquid fund
undistributed amount’ means, with respect to
any illiquid asset donor advised fund of a spon-
soring organization for any taxable year, the
amount by which—
‘‘(i) the illiquid fund distributable
amount for such taxable year, exceeds
‘‘(ii) the qualifying distributions made
during such taxable year and designated for
the purpose of reducing such amount.
‘‘(B) ILLIQUID
ASSET
DONOR
ADVISED
FUND.—The term ‘illiquid asset donor advised
fund’ means for any taxable year a donor ad-
vised fund the value of the illiquid assets of
which (as of the end of the preceding taxable
year) exceeds 10 percent of the value of the total
assets of such fund.
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‘‘(C) ILLIQUID ASSET.—The term ‘illiquid
asset’ means for any taxable year any asset other
than cash and marketable securities the value of
which is held for the entire taxable year as such
asset or any other illiquid asset.
‘‘(d) ORGANIZATION LEVEL DISTRIBUTABLE AMOUNT;
FUND LEVEL DISTRIBUTABLE AMOUNT; ILLIQUID FUND
DISTRIBUTABLE AMOUNT.—For purposes of this section—
‘‘(1) 
ORGANIZATION
LEVEL
DISTRIBUTABLE
AMOUNT.—The term ‘organization level distributable
amount’ means, with respect to any sponsoring orga-
nization for any taxable year, an amount equal to the
applicable percentage of the fair market value of the
aggregate assets of all donor advised funds main-
tained by such organization as determined on the last
day of the preceding taxable year (other than such
funds which have been in existence for less than 1
year as so determined).
‘‘(2) FUND
LEVEL
DISTRIBUTABLE
AMOUNT.—
The term ‘fund level distributable amount’ means,
with respect to any donor advised fund of any spon-
soring organization for any applicable 3-consecutive
taxable year period, an amount equal to the greater
of—
‘‘(A) $250, or