GKCCF (Deborah Wilkerson)

Summary: The Greater Kansas City Community Foundation opposes the proposed rules for bifurcated grants and public support treatment for DAF grants, arguing they create unnecessary administrative burdens and lack clarity. They advocate for a "bright-line" Section 170 analysis that allows DAFs to cover tax-deductible portions of fundraising events and suggest that DAF grants from public charities should be treated as coming from the public charity itself.