An organization is described in this subparagraph if the organization is a functionally integrated type III supporting organization (as defined under section 4943(f)(5)(B)).
26 U.S. Code § 4966. Taxes on taxable distributions
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(a) Imposition of taxes
(1) On the sponsoring organization
(2) On the fund management
(b) Special rulesFor purposes of subsection (a)—
(1) Joint and several liability
(c) Taxable distributionFor purposes of this section—
(1) In generalThe term “taxable distribution” means any distribution from a donor advised fund—
to any natural person, or
(d) DefinitionsFor purposes of this subchapter—
(1) Sponsoring organizationThe term “sponsoring organization” means any organization which—
is described in section 170(c) (other than in paragraph (1) thereof, and without regard to paragraph (2)(A) thereof),
maintains 1 or more donor advised funds.
(2) Donor advised fund
(A) In generalExcept as provided in subparagraph (B) or (C), the term “donor advised fund” means a fund or account—
which is owned and controlled by a sponsoring organization, and
(B) ExceptionsThe term “donor advised fund” shall not include any fund or account—
(ii) with respect to which a person described in subparagraph (A)(iii) advises as to which individuals receive grants for travel, study, or other similar purposes, if—
all grants from such fund or account are awarded on an objective and nondiscriminatory basis pursuant to a procedure approved in advance by the board of directors of the sponsoring organization, and such procedure is designed to ensure that all such grants meet the requirements of paragraph (1), (2), or (3) of section 4945(g).
(C) Secretarial authorityThe Secretary may exempt a fund or account not described in subparagraph (B) from treatment as a donor advised fund—
(3) Fund managerThe term “fund manager” means, with respect to any sponsoring organization—
(4) Disqualified supporting organization
(A) In generalThe term “disqualified supporting organization” means, with respect to any distribution—
any type III supporting organization (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 described in subparagraph (B) or (C) if—
(B) Type I and type II supporting organizationsAn organization is described in this subparagraph if the organization meets the requirements of subparagraphs (A) and (C) of section 509(a)(3) and is—
operated, supervised, or controlled by one or more organizations described in paragraph (1) or (2) of section 509(a), or
supervised or controlled in connection with one or more such organizations.
(C) Functionally integrated type III supporting organizations