One, Big, Beautiful Bill Frequently Asked Questions

As the One, Big, Beautiful bill containing the many Republican priorities moves through Congress under the reconciliation process, this page aims to answer frequently asked questions regarding the bill's key provisions impacting the philanthropic sector and charitable giving.

This page will be updated regularly as the legislation moves through the legislative process. View a full summary of the bill. For the most up to date information, join our Public Policy Action Network and sign up for Washington Snapshot to receive regular policy updates and stay engaged.

Last Updated on May 19, 2025.

Related Organizations

Assets of related organizations are aggregated with the assets of a private foundation for purposes of determining the applicable excise tax rate. Under the proposed legislation, a related organization is an organization (a) that controls or is controlled by the private foundation or (b) is controlled by one or more persons that also control the private foundation. This could apply to a large variety of tax-exempt and non-tax-exempt entities.

Corporations and Corporate Foundations:

• The general assets of corporations which have affiliated private foundations are unlikely to be included in a private foundation’s asset calculation. Unless the related organization is controlled by the private foundation in question, only assets of the related organization which are “intended or available for the use or benefit” of the private foundation will be aggregated under this provision. Most private corporate foundations do not control the company that established them, and the company’s general assets are not likely to be considered intended or available for use by the private foundation unless or until the company contributes any of its assets to the private foundation.

Public Charities, Community Foundations, and Donor-Advised Funds:

• It is unlikely that a community foundation or other public charity—even those which have received support from a private foundation—would be considered a related organization of a private foundation unless the public charity and private foundation are controlled by the same people. The mere presence of a board member of a private foundation on the board of a community foundation should not mean that it is a related organization. There would likely need to be significant overlap of the organizations’ boards so that the private foundation board members constitute a majority of the community foundation’s board and effectively control its actions.
• Assets in donor-advised funds that were established and/or advised by private foundations would not likely be aggregated with the private foundation’s assets because donor-advised funds are not legally controlled by the private foundation. Rather, the assets held in donor-advised funds are the legal property of the sponsoring public charity and under the control of that public charity.