864 
is operating consistent with the purposes or func-
tions constituting the basis for its exemption under 
section 501, or its status as an organization de-
scribed in section 509(a), of such Code, 
(3) whether the retention by donors to organi-
zations described in paragraph (1) of rights or privi-
leges with respect to amounts transferred to such or-
ganizations (including advisory rights or privileges 
with respect to the making of grants or the invest-
ment of assets) is consistent with the treatment of 
such transfers as completed gifts that qualify for a 
deduction for income, gift, or estate taxes, and 
(4) whether the issues raised by paragraphs 
(1), (2), and (3) are also issues with respect to other 
forms of charities or charitable donations. 
(b) REPORT.—Not later than 1 year after the date 
of the enactment of this Act, the Secretary of the Treasury 
shall submit to the Committee on Finance of the Senate 
and the Committee on Ways and Means of the House of 
Representatives a report on the study conducted under 
subsection (a) and make such recommendations as the 
Secretary of the Treasury considers appropriate. 
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ccoleman on PROD1PC71 with BILLS
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PART 2—IMPROVED ACCOUNTABILITY OF DONOR 
ADVISED FUNDS 
SEC. 1231. EXCISE TAXES RELATING TO DONOR ADVISED 
FUNDS. 
(a) IN GENERAL.—Chapter 42 (relating to private 
foundations and certain other tax-exempt organizations), 
as amended by the Tax Increase Prevention and Reconcili-
ation Act of 2005, is amended by adding at the end the 
following new subchapter: 
‘‘Subchapter G—Donor Advised Funds 
‘‘Sec. 4966. Taxes on taxable distributions. 
‘‘Sec. 4967. Taxes on prohibited benefits. 
‘‘SEC. 4966. TAXES ON TAXABLE DISTRIBUTIONS. 
‘‘(a) IMPOSITION OF TAXES.— 
‘‘(1) ON
THE
SPONSORING
ORGANIZATION.— 
There is hereby imposed on each taxable distribution 
a tax equal to 20 percent of the amount thereof. The 
tax imposed by this paragraph shall be paid by the 
sponsoring organization with respect to the donor 
advised fund. 
‘‘(2) ON THE FUND MANAGEMENT.—There is 
hereby imposed on the agreement of any fund man-
ager to the making of a distribution, knowing that 
it is a taxable distribution, a tax equal to 5 percent 
of the amount thereof. The tax imposed by this 
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paragraph shall be paid by any fund manager who 
agreed to the making of the distribution. 
‘‘(b) SPECIAL RULES.—For purposes of subsection 
(a)— 
‘‘(1) JOINT AND SEVERAL LIABILITY.—If more 
than one person is liable under subsection (a)(2) 
with respect to the making of a taxable distribution, 
all such persons shall be jointly and severally liable 
under such paragraph with respect to such distribu-
tion. 
‘‘(2) LIMIT FOR MANAGEMENT.—With respect 
to any one taxable distribution, the maximum 
amount of the tax imposed by subsection (a)(2) shall 
not exceed $10,000. 
‘‘(c) TAXABLE DISTRIBUTION.—For purposes of this 
section— 
‘‘(1) IN GENERAL.—The term ‘taxable distribu-
tion’ means any distribution from a donor advised 
fund— 
‘‘(A) to any natural person, or 
‘‘(B) to any other person if— 
‘‘(i) such distribution is for any pur-
pose other than one specified in section 
170(c)(2)(B), or 
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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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ccoleman on PROD1PC71 with BILLS
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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-
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ccoleman on PROD1PC71 with BILLS
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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.— 
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ccoleman on PROD1PC71 with BILLS
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‘‘(A) IN GENERAL.—The term ‘disqualified 
supporting organization’ means, with respect to 
any distribution— 
‘‘(i) any 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 
‘‘(ii) any organization which is de-
scribed in subparagraph (B) or (C) if— 
‘‘(I) the donor or any person des-
ignated by the donor for the purpose 
of advising with respect to distribu-
tions from a donor advised fund (and 
any related parties) directly or indi-
rectly controls a supported organiza-
tion (as defined in section 509(f)(3)) 
of such organization, or 
‘‘(II) the Secretary determines by 
regulations that a distribution to such 
organization otherwise is inappro-
priate. 
‘‘(B) TYPE I AND TYPE II SUPPORTING OR-
GANIZATIONS.—An organization is described in 
this subparagraph if the organization meets the 
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ccoleman on PROD1PC71 with BILLS
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requirements of subparagraphs (A) and (C) of 
section 509(a)(3) and is— 
‘‘(i) operated, supervised, or controlled 
by one or more organizations described in 
paragraph (1) or (2) of section 509(a), or 
‘‘(ii) supervised or controlled in con-
nection with one or more such organiza-
tions. 
‘‘(C) FUNCTIONALLY
INTEGRATED
TYPE 
III SUPPORTING ORGANIZATIONS.—An organiza-
tion is described in this subparagraph if the or-
ganization is a functionally integrated type III 
supporting organization (as defined under sec-
tion 4943(f)(5)(B)). 
‘‘SEC. 4967. TAXES ON PROHIBITED BENEFITS. 
‘‘(a) IMPOSITION OF TAXES.— 
‘‘(1) ON THE DONOR, DONOR ADVISOR, OR RE-
LATED PERSON.—There is hereby imposed on the 
advice of any person described in subsection (d) to 
have a sponsoring organization make a distribution 
from a donor advised fund which results in such per-
son or any other person described in subsection (d) 
receiving, directly or indirectly, a more than inci-
dental benefit as a result of such distribution, a tax 
equal to 125 percent of such benefit. The tax im-
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ccoleman on PROD1PC71 with BILLS
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posed by this paragraph shall be paid by any person 
described in subsection (d) who advises as to the dis-
tribution or who receives such a benefit as a result 
of the distribution. 
‘‘(2) ON THE FUND MANAGEMENT.—There is 
hereby imposed on the agreement of any fund man-
ager to the making of a distribution, knowing that 
such distribution would confer a benefit described in 
paragraph (1), a tax equal to 10 percent of the 
amount of such benefit. The tax imposed by this 
paragraph shall be paid by any fund manager who 
agreed to the making of the distribution. 
‘‘(b) EXCEPTION.—No tax shall be imposed under 
this section with respect to any distribution if a tax has 
been imposed with respect to such distribution under sec-
tion 4958. 
‘‘(c) SPECIAL RULES.—For purposes of subsection 
(a)— 
‘‘(1) JOINT AND SEVERAL LIABILITY.—If more 
than one person is liable under paragraph (1) or (2) 
of subsection (a) with respect to a distribution de-
scribed in subsection (a), all such persons shall be 
jointly and severally liable under such paragraph 
with respect to such distribution. 
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ccoleman on PROD1PC71 with BILLS
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‘‘(2) LIMIT FOR MANAGEMENT.—With respect 
to any one distribution described in subsection (a), 
the maximum amount of the tax imposed by sub-
section (a)(2) shall not exceed $10,000. 
‘‘(d) PERSON DESCRIBED.—A person is described in 
this subsection if such person is described in section 
4958(f)(7) with respect to a donor advised fund.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 4963 is amended by inserting 
‘‘4966, 4967,’’ after ‘‘4958,’’ each place it appears 
in subsections (a) and (c). 
(2) The table of subchapters for chapter 42 is 
amended by adding at the end the following new 
item: 
‘‘SUBCHAPTER G. DONOR ADVISED FUNDS’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 1232. EXCESS BENEFIT TRANSACTIONS INVOLVING 
DONOR ADVISED FUNDS AND SPONSORING 
ORGANIZATIONS. 
(a) DISQUALIFIED PERSONS.— 
(1) IN
GENERAL.—Paragraph (1) of section 
4958(f) is amended by striking ‘‘and’’ at the end of 
subparagraph (B), by striking the period at the end 
of subparagraph (C) and inserting a comma, and by 
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ccoleman on PROD1PC71 with BILLS
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adding after subparagraph (C) the following new 
subparagraphs: 
‘‘(D) which involves a donor advised fund 
(as defined in section 4966(d)(2)), any person 
who is described in paragraph (7) with respect 
to such donor advised fund (as so defined), and 
‘‘(E) which involves a sponsoring organiza-
tion (as defined in section 4966(d)(1)), any per-
son who is described in paragraph (8) with re-
spect to such sponsoring organization (as so de-
fined).’’. 
(2) DONORS, DONOR ADVISORS, AND INVEST-
MENT ADVISORS TREATED AS DISQUALIFIED PER-
SONS.—Section 4958(f) is amended by adding at the 
end the following new paragraphs: 
‘‘(7) DONORS AND DONOR ADVISORS.—For pur-
poses of paragraph (1)(E), a person is described in 
this paragraph if such person— 
‘‘(A) 
is 
described 
in 
section 
4966(d)(2)(A)(iii), 
‘‘(B) is a member of the family of an indi-
vidual described in subparagraph (A), or 
‘‘(C) is a 35-percent controlled entity (as 
defined in paragraph (3) by substituting ‘per-
sons described in subparagraph (A) or (B) of 
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ccoleman on PROD1PC71 with BILLS
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paragraph (7)’ for ‘persons described in sub-
paragraph (A) or (B) of paragraph (1)’ in sub-
paragraph (A)(i) thereof). 
‘‘(8) INVESTMENT ADVISORS.—For purposes of 
paragraph (1)(F)— 
‘‘(A) IN GENERAL.—A person is described 
in this paragraph if such person— 
‘‘(i) is an investment advisor, 
‘‘(ii) is a member of the family of an 
individual described in clause (i), or 
‘‘(iii) is a 35-percent controlled entity 
(as defined in paragraph (3) by sub-
stituting ‘persons described in clause (i) or 
(ii) of paragraph (8)(A)’ for ‘persons de-
scribed in subparagraph (A) or (B) of 
paragraph (1)’ in subparagraph (A)(i) 
thereof). 
‘‘(B) INVESTMENT
ADVISOR
DEFINED.— 
For purposes of subparagraph (A), the term 
‘investment advisor’ means, with respect to any 
sponsoring organization (as defined in section 
4966(d)(1)), any person (other than an em-
ployee of such organization) compensated by 
such organization for managing the investment 
of, or providing investment advice with respect 
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ccoleman on PROD1PC71 with BILLS
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to, assets maintained in donor advised funds 
(as defined in section 4966(d)(2)) owned by 
such organization.’’. 
(b) CERTAIN TRANSACTIONS TREATED AS EXCESS 
BENEFIT TRANSACTIONS.— 
(1) IN GENERAL.—Section 4958(c) is amended 
by redesignating paragraph (2) as paragraph (3) 
and by inserting after paragraph (1) the following 
new paragraph: 
‘‘(2) SPECIAL
RULES
FOR
DONOR
ADVISED 
FUNDS.—In the case of any donor advised fund (as 
defined in section 4966(d)(2))— 
‘‘(A) the term ‘excess benefit transaction’ 
includes any grant, loan, compensation, or other 
similar payment from such fund to a person de-
scribed in subsection (f)(7) with respect to such 
fund, and 
‘‘(B) the term ‘excess benefit’ includes, 
with respect to any transaction described in 
subparagraph (A), the amount of any such 
grant, loan, compensation, or other similar pay-
ment.’’. 
(2) SPECIAL RULE FOR CORRECTION OF TRANS-
ACTION.—Section 4958(f)(6) is amended by insert-
ing ‘‘, except that in the case of any correction of 
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an excess benefit transaction described in subsection 
(c)(2), no amount repaid in a manner prescribed by 
the Secretary may be held in any donor advised 
fund’’ after ‘‘standards’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to transactions occurring after the 
date of the enactment of this Act. 
SEC. 1233. EXCESS BUSINESS HOLDINGS OF DONOR AD-
VISED FUNDS. 
(a) IN GENERAL.—Section 4943 is amended by add-
ing at the end the following new subsection: 
‘‘(e) APPLICATION
OF TAX
TO DONOR ADVISED 
FUNDS.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, a donor advised fund (as defined in section 
4966(d)(2)) shall be treated as a private foundation. 
‘‘(2) DISQUALIFIED PERSON.—In applying this 
section to any donor advised fund (as so defined), 
the term ‘disqualified person’ means, with respect to 
the donor advised fund, any person who is— 
‘‘(A) 
described 
in 
section 
4966(d)(2)(A)(iii), 
‘‘(B) a member of the family of an indi-
vidual described in subparagraph (A), or 
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‘‘(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
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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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(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
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(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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(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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ccoleman on PROD1PC71 with BILLS
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taxable years ending after the date of the enactment 
of this Act. 
(b) MATTERS INCLUDED ON EXEMPT STATUS APPLI-
CATION.— 
(1) IN GENERAL.—Section 508 is amended by 
adding at the end the following new subsection: 
‘‘(f) ADDITIONAL PROVISIONS RELATING TO SPON-
SORING ORGANIZATIONS.—A sponsoring organization (as 
defined in section 4966(d)(1)) shall give notice to the Sec-
retary (in such manner as the Secretary may provide) 
whether such organization maintains or intends to main-
tain donor advised funds (as defined in section 
4966(d)(2)) and the manner in which such organization 
plans to operate such funds.’’. 
(2) EFFECTIVE DATE.—The amendment made 
by this subsection shall apply to organizations apply-
ing for tax-exempt status after the date of the enact-
ment of this Act. 
PART 3—IMPROVED ACCOUNTABILITY OF 
SUPPORTING ORGANIZATIONS 
SEC. 1241. REQUIREMENTS FOR SUPPORTING ORGANIZA-
TIONS. 
(a) TYPES OF SUPPORTING ORGANIZATIONS.—Sub-
paragraph (B) of section 509(a)(3) is amended to read 
as follows: 
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‘‘(B) is— 
‘‘(i) operated, supervised, or controlled 
by one or more organizations described in 
paragraph (1) or (2), 
‘‘(ii) supervised or controlled in con-
nection with one or more such organiza-
tions, or 
‘‘(iii) operated in connection with one 
or more such organizations, and’’. 
(b) REQUIREMENTS
FOR SUPPORTING ORGANIZA-
TIONS.—Section 509 (relating to private foundation de-
fined) is amended by adding at the end the following new 
subsection: 
‘‘(f) REQUIREMENTS FOR SUPPORTING ORGANIZA-
TIONS.— 
‘‘(1) TYPE III SUPPORTING ORGANIZATIONS.— 
For purposes of subsection (a)(3)(B)(iii), an organi-
zation shall not be considered to be operated in con-
nection with any organization described in para-
graph (1) or (2) of subsection (a) unless such orga-
nization meets the following requirements: 
‘‘(A) RESPONSIVENESS.—For each taxable 
year beginning after the date of the enactment 
of this subsection, the organization provides to 
each supported organization such information 
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as the Secretary may require to ensure that 
such organization is responsive to the needs or 
demands of the supported organization. 
‘‘(B) FOREIGN
SUPPORTED
ORGANIZA-
TIONS.— 
‘‘(i) IN GENERAL.—The organization 
is not operated in connection with any sup-
ported organization that is not organized 
in the United States. 
‘‘(ii) TRANSITION RULE FOR EXISTING 
ORGANIZATIONS.—If the organization is 
operated in connection with an organiza-
tion that is not organized in the United 
States on the date of the enactment of this 
subsection, clause (i) shall not apply until 
the first day of the third taxable year of 
the organization beginning after the date 
of the enactment of this subsection. 
‘‘(2) ORGANIZATIONS
CONTROLLED
BY
DO-
NORS.— 
‘‘(A) IN GENERAL.—For purposes of sub-
section (a)(3)(B), an organization shall not be 
considered to be— 
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‘‘(i) operated, supervised, or controlled 
by any organization described in paragraph 
(1) or (2) of subsection (a), or 
‘‘(ii) operated in connection with any 
organization described in paragraph (1) or 
(2) of subsection (a), 
if such organization accepts any gift or con-
tribution from any person described in subpara-
graph (B). 
‘‘(B) PERSON
DESCRIBED.—A person is 
described in this subparagraph if, with respect 
to a supported organization of an organization 
described in subparagraph (A), such person 
is— 
‘‘(i) a person (other than an organiza-
tion described in paragraph (1), (2), or (4) 
of section 509(a)) who directly or indi-
rectly controls, either alone or together 
with persons described in clauses (ii) and 
(iii), the governing body of such supported 
organization, 
‘‘(ii) a member of the family (deter-
mined under section 4958(f)(4)) of an in-
dividual described in clause (i), or 
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‘‘(iii) a 35-percent controlled entity 
(as defined in section 4958(f)(3) by sub-
stituting ‘persons described in clause (i) or 
(ii) of section 509(f)(2)(B)’ for ‘persons 
described in subparagraph (A) or (B) of 
paragraph (1)’ in subparagraph (A)(i) 
thereof). 
‘‘(3) SUPPORTED
ORGANIZATION.—For pur-
poses of this subsection, the term ‘supported organi-
zation’ means, with respect to an organization de-
scribed in subsection (a)(3), an organization de-
scribed in paragraph (1) or (2) of subsection (a)— 
‘‘(A) for whose benefit the organization de-
scribed in subsection (a)(3) is organized and 
operated, or 
‘‘(B) with respect to which the organiza-
tion performs the functions of, or carries out 
the purposes of.’’. 
(c) CHARITABLE TRUSTS WHICH ARE TYPE III SUP-
PORTING
ORGANIZATIONS.—For purposes of section 
509(a)(3)(B)(iii) of the Internal Revenue Code of 1986, 
an organization which is a trust shall not be considered 
to be operated in connection with any organization de-
scribed in paragraph (1) or (2) of section 509(a) of such 
Code solely because— 
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ccoleman on PROD1PC71 with BILLS
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(1) it is a charitable trust under State law, 
(2) the supported organization (as defined in 
section 509(f)(3) of such Code) is a beneficiary of 
such trust, and 
(3) the supported organization (as so defined) 
has the power to enforce the trust and compel an ac-
counting. 
(d) PAYOUT REQUIREMENTS
FOR TYPE III SUP-
PORTING ORGANIZATIONS.— 
(1) IN GENERAL.—The Secretary of the Treas-
ury shall promulgate new regulations under section 
509 of the Internal Revenue Code of 1986 on pay-
ments required by type III supporting organizations 
which are not functionally integrated type III sup-
porting organizations. Such regulations shall require 
such organizations to make distributions of a per-
centage of either income or assets to supported orga-
nizations (as defined in section 509(f)(3) of such 
Code) in order to ensure that a significant amount 
is paid to such organizations. 
(2) TYPE
III
SUPPORTING
ORGANIZATION; 
FUNCTIONALLY INTEGRATED TYPE III SUPPORTING 
ORGANIZATION.—For purposes of paragraph (1), the 
terms ‘‘type III supporting organization’’ and ‘‘func-
tionally integrated type III supporting organization’’ 
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have the meanings given such terms under subpara-
graphs (A) and (B) section 4943(f)(5) of the Inter-
nal Revenue Code of 1986 (as added by this Act), 
respectively. 
(e) EFFECTIVE DATES.— 
(1) IN GENERAL.—The amendments made by 
subsections (a) and (b) shall take effect on the date 
of the enactment of this Act. 
(2) CHARITABLE TRUSTS WHICH ARE TYPE III 
SUPPORTING ORGANIZATIONS.—Subsection (c) shall 
take effect— 
(A) in the case of trusts operated in con-
nection with an organization described in para-
graph (1) or (2) of section 509(a) of the Inter-
nal Revenue Code of 1986 on the date of the 
enactment of this Act, on the date that is one 
year after the date of the enactment of this Act, 
and 
(B) in the case of any other trust, on the 
date of the enactment of this Act. 
SEC. 1242. EXCESS BENEFIT TRANSACTIONS INVOLVING 
SUPPORTING ORGANIZATIONS. 
(a) DISQUALIFIED PERSONS.—Paragraph (1) of sec-
tion 4958(f), as amended by this Act, is amended by re-
designating subparagraphs (D) and (E) as subparagraphs 
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ccoleman on PROD1PC71 with BILLS
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(E) and (F), respectively, and by adding after subpara-
graph (C) the following new subparagraph: 
‘‘(D) any person who is described in sub-
paragraph (A), (B), or (C) with respect to an 
organization described in section 509(a)(3) and 
organized and operated exclusively for the ben-
efit of, to perform the functions of, or to carry 
out the purposes of the applicable tax-exempt 
organization.’’. 
(b) CERTAIN TRANSACTIONS TREATED AS EXCESS 
BENEFIT TRANSACTIONS.—Section 4958(c), as amended 
by this Act, is amended by redesignating paragraph (3) 
as paragraph (4) and by inserting after paragraph (2) the 
following new paragraph: 
‘‘(3) SPECIAL RULES FOR SUPPORTING ORGANI-
ZATIONS.— 
‘‘(A) IN GENERAL.—In the case of any or-
ganization described in section 509(a)(3)— 
‘‘(i) the term ‘excess benefit trans-
action’ includes— 
‘‘(I) any grant, loan, compensa-
tion, or other similar payment pro-
vided by such organization to a person 
described in subparagraph (B), and 
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‘‘(II) any loan provided by such 
organization to a disqualified person 
(other than an organization described 
in paragraph (1), (2), or (4) of section 
509(a)), and 
‘‘(ii) the term ‘excess benefit’ includes, 
with respect to any transaction described 
in clause (i), the amount of any such 
grant, loan, compensation, or other similar 
payment. 
‘‘(B) PERSON
DESCRIBED.—A person is 
described in this subparagraph if such person 
is— 
‘‘(i) a substantial contributor to such 
organization, 
‘‘(ii) a member of the family (deter-
mined under section 4958(f)(4)) of an in-
dividual described in clause (i), or 
‘‘(iii) a 35-percent controlled entity 
(as defined in section 4958(f)(3) by sub-
stituting ‘persons described in clause (i) or 
(ii) of section 4958(c)(3)(B)’ for ‘persons 
described in subparagraph (A) or (B) of 
paragraph (1)’ in subparagraph (A)(i) 
thereof). 
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‘‘(C) SUBSTANTIAL
CONTRIBUTOR.—For 
purposes of this paragraph— 
‘‘(i) IN
GENERAL.—The term ‘sub-
stantial contributor’ means any person who 
contributed or bequeathed an aggregate 
amount of more than $5,000 to the organi-
zation, if such amount is more than 2 per-
cent of the total contributions and be-
quests received by the organization before 
the close of the taxable year of the organi-
zation in which the contribution or bequest 
is received by the organization from such 
person. In the case of a trust, such term 
also means the creator of the trust. Rules 
similar to the rules of subparagraphs (B) 
and (C) of section 507(d)(2) shall apply 
for purposes of this subparagraph. 
‘‘(ii) EXCEPTION.—Such term shall 
not include any organization described in 
paragraph (1), (2), or (4) of section 
509(a).’’. 
(c) EFFECTIVE DATES.— 
(1) SUBSECTION (a).—The amendments made 
by subsection (a) shall apply to transactions occur-
ring after the date of the enactment of this Act. 
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(2) SUBSECTION (b).—The amendments made 
by subsection (a) shall apply to transactions occur-
ring after July 25, 2006. 
SEC. 1243. EXCESS BUSINESS HOLDINGS OF SUPPORTING 
ORGANIZATIONS. 
(a) IN GENERAL.—Section 4943, as amended by this 
Act, is amended by adding at the end the following new 
subsection: 
‘‘(f) APPLICATION OF TAX TO SUPPORTING ORGANI-
ZATIONS.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, an organization which is described in para-
graph (3) shall be treated as a private foundation. 
‘‘(2) EXCEPTION.—The Secretary may exempt 
the excess business holdings of any organization 
from the application of this subsection if the Sec-
retary determines that such holdings are consistent 
with the purpose or function constituting the basis 
for its exemption under section 501. 
‘‘(3) ORGANIZATIONS DESCRIBED.—An organi-
zation is described in this paragraph if such organi-
zation is— 
‘‘(A) a type III supporting organization 
(other than a functionally integrated type III 
supporting organization), or 
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‘‘(B) an organization which meets the re-
quirements of subparagraphs (A) and (C) of 
section 509(a)(3) and which is supervised or 
controlled in connection with or one or more or-
ganizations described in paragraph (1) or (2) of 
section 509(a), but only if such organization ac-
cepts any gift or contribution from any person 
described in section 509(f)(2)(B). 
‘‘(4) DISQUALIFIED PERSON.— 
‘‘(A) IN GENERAL.—In applying this sec-
tion to any organization described in paragraph 
(3), the term ‘disqualified person’ means, with 
respect to the organization— 
‘‘(i) any person who was, at any time 
during the 5-year period ending on the 
date described in subsection (a)(2)(A), in a 
position to exercise substantial influence 
over the affairs of the organization, 
‘‘(ii) any member of the family (deter-
mined under section 4958(f)(4)) of an in-
dividual described in clause (i), 
‘‘(iii) any 35-percent controlled entity 
(as defined in section 4958(f)(3) by sub-
stituting ‘persons described in clause (i) or 
(ii) of section 4943(f)(4)(A)’ for ‘persons 
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described in subparagraph (A) or (B) of 
paragraph (1)’ in subparagraph (A)(i) 
thereof), 
‘‘(iv) any person described in section 
4958(c)(3)(B), and 
‘‘(v) any organization— 
‘‘(I) which is effectively con-
trolled (directly or indirectly) by the 
same person or persons who control 
the organization in question, or 
‘‘(II) substantially all of the con-
tributions to which were made (di-
rectly or indirectly) by the same per-
son or persons described in subpara-
graph (B) or a member of the family 
(within 
the 
meaning 
of 
section 
4946(d)) of such a person. 
‘‘(B) PERSONS DESCRIBED.—A person is 
described in this subparagraph if such person 
is— 
‘‘(i) a substantial contributor to the 
organization 
(as 
defined 
in 
section 
4958(c)(3)(C)), 
‘‘(ii) an officer, director, or trustee of 
the organization (or an individual having 
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powers or responsibilities similar to those 
of the officers, directors, or trustees of the 
organization), or 
‘‘(iii) an owner of more than 20 per-
cent of— 
‘‘(I) the total combined voting 
power of a corporation, 
‘‘(II) the profits interest of a 
partnership, or 
‘‘(III) the beneficial interest of a 
trust or unincorporated enterprise, 
which is a substantial contributor (as so 
defined) to the organization. 
‘‘(5) TYPE
III
SUPPORTING
ORGANIZATION; 
FUNCTIONALLY INTEGRATED TYPE III SUPPORTING 
ORGANIZATION.—For purposes of this subsection— 
‘‘(A) TYPE
III
SUPPORTING
ORGANIZA-
TION.—The term ‘type III supporting organiza-
tion’ means an organization which meets the re-
quirements of subparagraphs (A) and (C) of 
section 509(a)(3) and which is operated in con-
nection with one or more organizations de-
scribed in paragraph (1) or (2) of section 
509(a). 
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‘‘(B) FUNCTIONALLY
INTEGRATED
TYPE 
III
SUPPORTING
ORGANIZATION.—The term 
‘functionally integrated type III supporting or-
ganization’ means a type III supporting organi-
zation which is not required under regulations 
established by the Secretary to make payments 
to supported organizations (as defined under 
section 509(f)(3)) due to the activities of the 
organization related to performing the functions 
of, or carrying out the purposes of, such sup-
ported organizations. 
‘‘(6) SPECIAL RULE FOR CERTAIN HOLDINGS 
OF
TYPE
III
SUPPORTING
ORGANIZATIONS.—For 
purposes of this subsection, the term ‘excess busi-
ness holdings’ shall not include any holdings of a 
type III supporting organization in any business en-
terprise if, as of November 18, 2005, the holdings 
were held (and at all times thereafter, are held) for 
the benefit of the community pursuant to the direc-
tion of a State attorney general or a State official 
with jurisdiction over such organization. 
‘‘(7) PRESENT
HOLDINGS.—For purposes of 
this subsection, rules similar to the rules of para-
graphs (4), (5), and (6) of subsection (c) shall apply 
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to organizations described in section 509(a)(3), ex-
cept 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. 1244. TREATMENT OF AMOUNTS PAID TO SUPPORTING 
ORGANIZATIONS BY PRIVATE FOUNDATIONS. 
(a) QUALIFYING DISTRIBUTIONS.—Paragraph (4) of 
section 4942(g) is amended to read as follows: 
‘‘(4) LIMITATION ON DISTRIBUTIONS BY NON-
OPERATING PRIVATE FOUNDATIONS TO SUPPORTING 
ORGANIZATIONS.— 
‘‘(A) IN GENERAL.—For purposes of this 
section, the term ‘qualifying distribution’ shall 
not include any amount paid by a private foun-
dation which is not an operating foundation 
to— 
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‘‘(i) any 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 
‘‘(ii) any organization which is de-
scribed in subparagraph (B) or (C) if— 
‘‘(I) a disqualified person of the 
private foundation directly or indi-
rectly controls such organization or a 
supported organization (as defined in 
section 509(f)(3)) of such organiza-
tion, or 
‘‘(II) the Secretary determines by 
regulations that a distribution to such 
organization otherwise is inappro-
priate. 
‘‘(B) TYPE I AND TYPE II SUPPORTING OR-
GANIZATIONS.—An organization is described in 
this subparagraph if the organization meets the 
requirements of subparagraphs (A) and (C) of 
section 509(a)(3) and is— 
‘‘(i) operated, supervised, or controlled 
by one or more organizations described in 
paragraph (1) or (2) of section 509(a), or 
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‘‘(ii) supervised or controlled in con-
nection with one or more such organiza-
tions. 
‘‘(C) FUNCTIONALLY
INTEGRATED
TYPE 
III SUPPORTING ORGANIZATIONS.—An organiza-
tion is described in this subparagraph if the or-
ganization is a functionally integrated type III 
supporting organization (as defined under sec-
tion 4943(f)(5)(B)).’’. 
(b) TAXABLE EXPENDITURES.—Subparagraph (A) 
of section 4945(d)(4) is amended to read as follows: 
‘‘(A) such organization— 
‘‘(i) is described in paragraph (1) or 
(2) of section 509(a), 
‘‘(ii) is an organization described in 
section 509(a)(3) (other than an organiza-
tion described in clause (i) or (ii) of section 
4942(g)(4)(A)), or 
‘‘(iii) is an exempt operating founda-
tion (as defined in section 4940(d)(2)), 
or’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to distributions and expenditures 
after the date of the enactment of this Act. 
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