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SECTION 4. CERTAIN

Internal Revenue Bulletin 2017-51 · 2026-10-03 edition · updated 2026-10-04 · United States

DISTRIBUTIONS FROM A DAF PERMITTED WITHOUT REGARD TO A CHARITABLE PLEDGE MADE BY A DONOR, DONOR ADVISOR, OR RELATED PERSON

Commenters have expressed uncertainty about whether a Donor/Advisor may advise a distribution from a DAF to satisfy a Donor/Advisor’s pledge to make a contribution to a charity. Commenters noted that under § 4941, a private foundation’s grant or other payment in fulfillment of the legal obligation of a disqualified person ordinarily constitutes a prohibited act of self-dealing. See § 53.4941(d)–2(f)(1) of the Excise Tax Regulations.

December 18, 2017 564 Bulletin No. 2017–51

sponsoring organization identifies B as the individual who advised the distribution, but makes no reference to a charitable pledge by B or any other person. Z chooses to treat the sponsoring organization’s distribution as satisfying B’s pledge. Z also publicly recognizes B for B’s role in facilitating the distribution from the sponsoring organization, but Z provides no other benefit to B. B does not attempt to claim a § 170 deduction with respect to the distribution. Under these facts, the Treasury Department and the IRS are currently of the view that the DAF distribution does not result in a more than incidental benefit to B under § 4967 merely because Z treats the distribution as satisfying B’s pledge.

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▸Contents — Internal Revenue Bulletin 2017-51
Internal Revenue Bulletin 2017-51

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