Notice 2017-73

Schwab Charitable, a tax-exempt public charity that administers donor-advised funds (DAFs), opposes the proposed regulatory burdens and treatment of DAFs as similar to private foundations. They argue that DAFs are already compliant, and that the proposed rules—specifically regarding bifurcated gifts, pledges, and public support—would create unnecessary administrative burdens and reduce the efficiency of charitable giving.

Schwab Charitable, a tax-exempt public charity, opposes the proposed regulations in Notice 2017-73 that would impose additional regulatory burdens on donor-advised funds (DAFs) similar to those on private foundations. They argue that DAFs are already compliant, and that the proposed rules—specifically regarding "bifurcated gifts," pledges, and public support—would create unnecessary administrative burdens, undermine donor privacy, and reduce the efficiency of charitable giving.

National Philanthropic Trust (NPT), a charitable sponsor of donor-advised funds (DAFs), submitted comments regarding IRS Notice 2017-73. The organization argues that DAFs should not be treated like private foundations, disagrees with specific proposed rules regarding bifurcated distributions and pledge references, and suggests that proposed public support limitations are overly broad.

Fidelity Charitable, an independent public charity, opposes the proposed regulations in Notice 2017-73, arguing that they incorrectly import private foundation rules onto donor-advised funds (DAFs). The organization contends that the proposed rules are unwarranted, overly burdensome, and lack a basis in statutory authority or evidence of abuse.