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Coming Together, Not Apart, is a three-publication series exploring philanthropy's involvement in developing the heartset, mindset, and skillset to lead collaboratively across differences. Specifically:Part 1: How Philanthropy Supports Connection in a Time of Dangerous DivisionComing…
Coming Together, Not Apart: How Philanthropy Supports Connection in a Time of Dangerous Division is the first of three Council on Foundations publications exploring philanthropy's involvement in developing the heartset, mindset, and skillset to lead collaboratively across differences. It dives deep…
Coming Together, Not Apart: Inside the Work of Turning Conflict Into Collaboration is the second of three Council on Foundations publications exploring philanthropy's involvement in developing the heartset, mindset, and skillset to lead collaboratively across differences. It dives deep into how…
Internal Revenue Code § 4945(e) allows private foundations to appear or communicate with a legislative body concerning a decision of that body that might affect the existence of the foundation, its powers and duties, its tax-exempt status, or the deductibility of contributions to it.
What…
Developed for the Council on Foundations by Christopher J. Armstrong, Partner at Holland & Knight
The Current Environment
Foundations are under increasing political scrutiny regarding their relationships with organizations that have engaged in protests, especially in situations where…
Increasing taxes on private foundations means fewer dollars to charitable organizations, from food pantries to disaster relief groups. The below data from Candid shows that in almost every state, private foundations will have to pay millions more in taxes, crippling their ability to respond to the…
In September 2023, a group of 15 foundations joined 20 bilateral donors in signing a Donor Statement committing to advancing locally led development. After recent global shifts in foreign assistance and the dismantling of USAID, the Council on Foundations wanted to understand how philanthropy has…
This page outlines the range of purposes that qualify an organization for tax exemption under section 501(c)(3) of the Internal Revenue Code. It explains how the IRS and courts interpret key terms — especially "charitable" — and how those interpretations shape eligibility.
Permissible Exempt…
Community Foundations and other public charities may engage in an insubstantial amount of lobbying as part of normal operations. But what are the rules around engaging in self-defense?
Internal Revenue Code Section 4911(d)(2)(C) provides public charities with an exception to the…
Self-Defense Exception: A legislative proposal to modify the private foundation excise tax on net investment income under IRC section 4940 would qualify as a self-defense issue, because it affects a private foundation’s duties. Private foundations may therefore communicate with the legislature, its…