Supporting the Supporting Organization: The Potential and Exploitation of 509(A)(3) Charities
Alyssa A. DiRusso
Samford University - Cumberland School of Law
Indiana Law Review, Vol. 39, March 2006
Supporting organizations, a type of charity defined in section 509(a)(3) of the Internal Revenue Code, have vast potential for philanthropic impact but perhaps equally vast potential for abuse. Donors who establish supporting organizations may retain inappropriate levels of control over the assets they contribute, or may purloin charitable funds for their personal uses. This article discusses the complex tax rules that apply to supporting organizations and explains their unique role in charitable giving. It then explores the allegations of abuse in the supporting organization realm and reviews current proposals for reforming the system. The article concludes by proposing that the public disclosure rules be amended to require greater transparency of the activities of supporting organizations and greater dispersement of this information.
Number of Pages in PDF File: 46
Keywords: supporting organization, charity, 509(a)(3), disclosure, accountability
JEL Classification: K99, K34, L3, L30, L31Accepted Paper Series
Date posted: October 21, 2005 ; Last revised: September 12, 2010
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