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An estimated $1.7 trillion in donations, ostensibly earmarked for philanthropy, are currently languishing in private foundations and donor-advised funds—while charities like Feeding America and Habitat for Humanity are under-resourced.
Thanks to outdated charity tax laws, the U.S. is missing out on hundreds of billions of dollars that could flow toward housing and food security, health research, education, advocacy, and other crucial nonprofit efforts aimed at uplifting the common good—but simple reforms could unlock some of the extreme wealth that is currently "warehoused" in private foundations and donor-advised funds.
This is according to a new Institute for Policy Studies analysis that shows charitable groups currently hold an estimated $1.7 trillion in donations that are "ostensibly earmarked for philanthropy," but are able to "languish in go-between funds" while working charities remain under-resourced.
The foundations and donor-advised funds (DAFs) are able to collect tax breaks while sitting on billions of dollars thanks to provisions in the Tax Reform Act of 1969 that haven't been updated in decades, wrote IPS associate fellow Helen Flannery and associate director of charity reform initiatives Bella DeVaan at Inequality.org, a project of the organization.
"Initially, in the Tax Reform Act of 1969, private foundations were mandated to give away 6 percent of their wealth or the annual net growth from their investments: Whichever was higher," wrote Flannery and DeVaan. "Foundations' tax benefits wouldn't provide license for funds to just grow forever and ever, and they were to be consistently responsive to shifting economic reality. A decade of revisions to payout requirements reflected those principles and eventually created our flat 5% mandate. But that 5% is overdue for re-evaluation, and our elected representatives have fallen asleep at the wheel."
"It's worth imagining a future in which billions more flow towards life-saving medical cures, food security, housing access, and environmental protection through organizations that are already woven into our social fabric."
While the nation's largest foundations give charitable donations at a rate of about 5%, "their gains in the market have averaged 9% over the last five years," they explained.
In other words, said Flannery and DeVaan, the funds "are growing faster than the rate at which they give" while donations to working charities like Habitat for Humanity, United Way, and Feeding America fall behind.
The wealth of DAFs has skyrocketed by 411% in the last decade, with the funds stockpiling an estimated $230 billion in assets in 2023.
IPS noted that billions of dollars in DAF gifts have been directed as dark money contributions—whose donors "might well have second thoughts" if tax laws were reformed to require both boosted payouts and more transparency.
In its policy brief, IPS proposes reforms that would:
"It's worth imagining a future in which billions more flow towards life-saving medical cures, food security, housing access, and environmental protection through organizations that are already woven into our social fabric," wrote Flannery and DeVaan, "or organizations that could and should be with strengthened access to funding."
IPS released the analysis as legislators prepare to overhaul the tax code in 2025.
"We're hopeful that this can be a watershed moment for charity reform akin to 1969," wrote Flannery and DeVaan, along with IPS program director Chuck Collins.
We fill up the soul of communities by giving what we can. It's not charity, but simply being a good neighbor.
Civilization has been described as “the slow process of learning to be kind.” This past summer and early fall, while I stood with peace and justice companions on the Greenfield Commons in Greenfield Massachusetts, I witnessed a pervasive culture of kindness.
Karen Boyden, with the assistance of some family and friends, folded and laid out free shoes and summer clothes and, later, fall sweaters, pants and heavier shoes on a table and blanket on the Commons. A sign welcomed all passing by to help themselves to “Dippy’s Closet.” Some who chose clothing and shoes, with the advice of friends, left with smiles; others were discreet, not wanting to draw attention to themselves.
Dippy's Closet, I learned from Karen, is a grassroots volunteer driven outreach that provides free clothing for men, women, and children with the specific goal “to attract homeless folks and individual and families who are struggling financially to purchase quality clothing.” She was first inspired to share her father's wardrobe when he unexpectedly passed in Sept of 2022; and she began donating his wardrobe to men living in a recovery home in Greenfield. “It was a great way to rechannel the pain of losing my dad into helping others,” especially seeing “so many people living on the streets of Greenfield.”
Karen estimates that, in their 9 outreaches on the Commons from June to early November, about 50 people have visited weekly and left with clothing. She has widened the circle of donors, including co-workers at the Valley Medical Group Easthampton and the Giving Circle Thrift Shop of South Deerfield.
Asked what this act of kindness for other fellow humans means for her, she replied “I want to show the folks who are struggling that we do notice, that we do care and they are valued. It is my hope that our little clothing mission might inspire others to serve the homeless. It is not that hard and so incredibly rewarding....”
Karen mentioned being inspired by the Stone Soup Café, seeing their efforts to serve folks in need. And I noticed that some who stopped by Pippy’s Closet then headed to Stone Soup Café, one long block away, for a gourmet, healthy lunch, offered each Saturday from noon to 1:30.
This pay-what-you can community cafe, whose intent is “to build a culture of belonging,” has grown since its opening in 2010 from serving 25 meals to 600 meals each week. Their Community Free Store, an emergency curbside food pantry, was created at the prompting of their guests during the onset of the pandemic. It provides between 80-110 households with groceries, produce and personal care items at no charge to them. In 2022 Stone Soup created a tuition-free 12-week Culinary Institute program career training to people seeking a new career path, especially those who are seeking employment after a period of incarceration or recovery from addiction. Those accepted into the program leave with a Food Handlers License, a ServSafe Certificate in Kitchen Management, job skills, practicum experience, and references for securing work in the food sector of Franklin County.
Explaining her intense commitment, co-director and chef, Kirsten Levitt said; “My life’s passion is to service…humans are hardwired for service.” Head of Volunteers, Sarah Hilliard, is motivated by “a lot of love. No human being should be without food.”
Nearby in the Second Congregational Church, Gloria Matlock and volunteer tutors work with up to 20 children, to augment their chances to thrive as they grow in the innovative Twice As Smart program founded by Matlock in 2018. Her lofty four-fold mission is to:
Some Twice As Smart students are immigrants and many live in public housing.
This model of holistic education is clearing the students’ obstacle-laden path to higher education, jobs and a deep sense of self, a cause to which artist, musician, and former teacher Gloria Matlock has committed her life.
Are these programs using charity to remedy social injustice, as some might claim? Jane Addams would disagree. In 1892, this eminent social reformer explained that Hull House, her settlement house in a poor precinct of Chicago, was not a charity. Its purpose — and, for Addams, a central obligation of being a citizen — was to help America’s less fortunate make the most of themselves. “To call this effort [charity]…is to underestimate the duties of good citizenship.”
I would add that, with one-half of Americans either poor or a medical emergency away from economic ruin, these programs in our midst and the thousands like them across our country are beacons of civilization in a nation that pumps the world full of military weapons, while its soul empties from within.
Because DAFs have no payout requirement, the money often fails to move in a timely way to charities addressing urgent needs.
Last year, we wrote about how donor-advised funds, or DAFs, had become the top recipients of charitable giving in the United States. At the time, we were astounded to discover that DAF sponsors made up 6 of the top 10 and 9 of the top 20 most successful public-charity fundraisers in the country.
We’ve updated the data for 2021—the most recent year for which complete data is available—and the picture has only gotten more stark. Donor-advised fund sponsors now make up 7 of the top 10 and 11 of the top 20 public charities in the United States.
Public charities are nonprofits that rely on a broad base of donors for their revenue —as opposed to private foundations, which are usually created and supported by just one or two major donors.
In contrast to private foundations, DAF sponsors qualify as public charities, and so receive the same preferential tax treatment as working charities.
As we have reported before, DAFs are growing explosively. The assets held in U.S. DAFs have grown by 513% over the past 10 years—rocketing from $38 billion in 2011 to $234 billion in 2021.
And DAFs now rake in 22% of all U.S. individual charitable giving.
Donors can claim substantial charitable tax benefits for their contributions to DAFs, but, because DAFs have no payout requirement, the money often fails to move in a timely way to charities addressing urgent needs.
Through the charitable tax deduction, taxpayers subsidize contributions to DAFs by up to 74 cents on the dollar.
Of particular concern are DAF sponsors that are affiliated with for-profit Wall Street financial corporations. As we have documented, these commercial DAFs provide enormous publicly subsidized tax benefits to their high-rolling contributors while actively encouraging the warehousing of charitable wealth.
And commercial DAFs have been growing explosively. The Fidelity Charitable Gift Fund, for example, has been the most successful charitable fundraiser in the country for the past six years.
In 2021, Fidelity extended its lead by pulling in $15 billion—more than $11 billion more than the top working nonprofit, Feeding America.
We counted the Silicon Valley Community Foundation and the Chicago Community Trust as DAF sponsors because contributions to DAFs made up 93% and 97%, respectively, of their total incoming contributions in 2021.
Some of the operating nonprofits on this list—such as the United Way and Stanford University—sponsor DAF programs as well, but we did not categorize them as sponsors because their DAF programs are relatively tiny compared to their other fundraising.
It is also worth noting that DAFs may have actually done even better relative to working charities than our ranking shows. In previous years, the Chronicle of Philanthropy has made it easy for everyone to evaluate cash contributions by publishing well-researched lists of top-earning non-DAF “cause-driven” charities, but they did not do that in 2021.
So we compiled our current rankings by pulling contribution information from the tax returns of the largest DAF sponsors in the U.S., and then combining that with lists of donations to operating charities from two separate sources: Bloomberg’s ranking of the top-fundraising nonprofit universities and Forbes’ list of the top-fundraising non-university charities.
The Chronicle’s lists only included cash donations, however, while Forbes’ list includes both cash and noncash donations—and that can inflate revenue numbers, particularly for relief organizations. If Forbes’ list had only included cash donations to Feeding America, for example, they would have slipped out of the top 20.
Through the charitable tax deduction, taxpayers subsidize contributions to DAFs by up to 74 cents on the dollar.
This gives us all an interest in making sure that the money stored in DAFs is actually used for the greater good, rather than serving as a tax avoidance vehicle for the wealthy or lining the pockets of commercial money managers.
It’s time to move the money out of DAFs—and we’ve outlined a number of reforms that would make this happen.