Beyond Grantmaking: Additional Mechanisms for Mission

121914291-copy34th Annual Nonprofit Organizations Institute, Austin, Texas, 01/13/2017, (co-presented with James P. Joseph of Arnold & Porter LLP)

In the spirit of “thinking outside the box while working within the rules,” this presentation explores options for foundations to pursue in order to maximize their missions by going beyond or supplementing traditional grant making initiatives while still maintaining compliance with the private foundation prohibited transaction rules.  Key topics explored include a discussion of the basic parameters of the private foundation rules; alternatives to traditional private foundations, including foundations that engage in direct charitable activities, medical research organizations, charitable joint ventures and more; and program- and mission-related investments.  Additional information may be found in the related reference outline, Beyond Grantmaking: Additional Mechanisms for Mission.

When Giving Money Isn’t Enough: Direct Charitable Activities of Private Foundations

2015 Tax Seminar (Salk Institute), La Jolla, California

92969426 - CopyYour foundation wants to go beyond its grant-making programs and increase its involvement, perhaps through leveraging your expertise, supplementing your grant-making dollars, and/or investing strategically and programmatically.  But how do you expand while still being subject to the prohibited transaction rules set out in the Internal Revenue Code?  This paper and presentation examine key issues of direct charitable activities, program-related investments, advantages and disadvantages of private operating foundations, and use of separate and subsidiary entities for related activities.