Donor advised fund documentation met the written acknowledgment requirements

Plain-English summary

Chief Counsel reviewed whether a taxpayer had obtained the contemporaneous written acknowledgment required to substantiate a charitable deduction for a contribution to a donor advised fund. After reviewing additional information and discussing the facts and authorities, Counsel concluded that the sponsoring organization's documentation met the requirements cited in sections 170(f)(8)(C) and 170(f)(18)(b). The advice applies only to the documentation in this case.

Ruling snapshot

• Question: Did the sponsoring organization's documentation satisfy the contemporaneous written acknowledgment requirements for the taxpayer's donor advised fund contribution?
• Outcome: advice given
• Key authorities: IRC §§ 170(f)(8)(C), 170(f)(18)(b)

Full text (IRS public release)

ID:        CCA_2017052209250619
UILC:      170.12-09

Number: 201736023
Release Date: 9/8/2017
From:
Sent: Monday, May 22, 2017 9:25:06 AM
To:
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Subject: -----------------------------------------


Hi ---------- – I’ve reviewed the additional information that you sent me and discussed the
facts and authorities with my reviewer regarding whether taxpayer complied with the
requirement to obtain a contemporaneous written acknowledgement for purposes of
substantiating its charitable deduction under the special requirements for contributions
to donor advised funds under §170(f). As we discussed on September 19th, we
believe the language in the sponsoring organization’s documentation meets the
requirements of both § 170(f)(8)(C) and § 170(f)(18)(b) for a contemporaneous written
acknowledgement in this case. Please let us know if you have further questions.

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