# Private Foundation vs. Donor Advised Fund: Control, Deductions, 2026 Rules and California

> Private foundation vs. donor advised fund in 2026: control, 60/30/20 limits, the new 0.5% floor, 1.39% tax, 5% payout, self-dealing and California rules.

Source: https://ridleylawoffices.com/private-foundation-vs-donor-advised-fund/

By Eric Ridley, attorney, Ridley Law. Updated October 2026.

**Who this page is for:** Every estate band. A donor advised fund works at almost any size. A private foundation usually belongs in the $15 million to $100 million band and above, where a family wants its own board, its own staff, and a giving program that will outlive the founders. That band is Ridley Law’s judgment, not a legal threshold.

A private foundation is a charity your family controls. Your board picks the grants, hires the staff, and runs the investments. In exchange it pays a 1.39% tax on investment income, must pay out about 5% of its investment assets each year, files a public Form 990-PF, and lives under strict self-dealing rules. A donor advised fund is an account at a public charity. You recommend grants, but the sponsor has the final say. It costs less, keeps your giving private, and gets better deduction limits: 60% of income for cash and fair market value for appreciated stock, against 30% and often only basis for a foundation. A foundation earns its cost when control and permanence matter more to you than the deduction and the expense.

**1.39%**

Federal excise tax on a private foundation’s net investment income (IRC § 4940(a)). The 2025 tax law left it unchanged

**5%**

Minimum investment return a private foundation must pay out each year (IRC § 4942(e))

**60% vs. 30%**

Cash deduction limit for gifts to a DAF vs. a private foundation, as a share of AGI (IRC § 170(b)(1))

**0.5%**

New floor on itemized charitable deductions starting in 2026 (Pub. L. 119-21, § 70425)

## Who has the final say over the money

A private foundation’s board decides who gets grants, who is hired and how the money is invested. In a donor advised fund the sponsor makes those calls. A private foundation is a charity your family owns and runs, while a donor advised fund is an account that a public charity owns and controls, with you holding only advisory privileges over grants and investments ([IRC § 4966(d)(2)](https://www.law.cornell.edu/uscode/text/26/4966), 2026).

Because the sponsor of a DAF is a public charity, gifts to it get public-charity deduction limits. Because a foundation stays under family control, Congress taxes its investment income, forces a payout, and bars most dealings between the foundation and the family. A DAF tends to win on the deduction and a foundation on control. For the everyday questions people ask about DAFs, see [donor advised funds: what Reddit gets right and wrong](https://ridleylawoffices.com/guides/donor-advised-fund-reddit/). If the goal is income for life with charity taking what’s left, a [charitable remainder trust](https://ridleylawoffices.com/charitable-remainder-trust-attorney-california/) is a different tool.

The control a DAF donor gives up is real. The deduction for a gift to a DAF requires a written acknowledgment from the sponsor “that such organization has exclusive legal control over the assets contributed” ([IRC § 170(f)(18)(B)](https://www.law.cornell.edu/uscode/text/26/170)). The statute defines a DAF as a fund owned and controlled by the sponsoring organization, over which the donor has, or reasonably expects to have, advisory privileges ([IRC § 4966(d)(2)(A)](https://www.law.cornell.edu/uscode/text/26/4966)).

Donors have tested that line in the Northern District of California and the Ninth Circuit, and lost. In [Pinkert v. Schwab Charitable Fund, 48 F.4th 1051 (9th Cir. 2022)](https://cdn.ca9.uscourts.gov/datastore/opinions/2022/09/14/21-16299.pdf), a donor sued over Schwab Charitable’s investment pools and fees. The Ninth Circuit held he lacked Article III standing, because Schwab’s program policies gave it exclusive legal control and he kept only a nonbinding right to advise, which he didn’t claim Schwab ignored. In [Fairbairn v. Fidelity Investments Charitable Gift Fund](https://www.courtlistener.com/opinion/9600254/fairbairn-v-fidelity-investments-charitable-gift-fund/), No. 18-cv-04881-JSC (N.D. Cal. Feb. 26, 2021), former hedge fund managers gave about 1.93 million Energous shares to their DAF on December 28 and 29, 2017. Fidelity Charitable sold them all on December 29, at an average price about 30% below the prior day’s close, consistent with its published policy of selling donated shares as soon as possible. After a bench trial, the court entered judgment for the sponsor on every claim. It found the donors hadn’t proved most of the promises they alleged, and that the sale followed the sponsor’s published policy without breaching any duty of care.

## What the choice does to your deduction

A married couple with $5,000,000 of adjusted gross income who give $1,000,000 of stock with a $100,000 basis in 2026 can see the deduction swing from $975,000 to $75,000, depending on the asset and who receives it. Given to a DAF, the stock produces a $975,000 deduction after the 0.5% floor, whether it is listed or closely held, and saves about $341,250 in federal tax. Given to their own private foundation, listed stock does as well, but closely held stock produces a deduction of $75,000 and saves $26,250.

Percentage limits favor the DAF, 60% of income for cash against 30% for a foundation. Cash gifts to public charities, including DAF sponsors, are deductible up to 60% of your contribution base, which is generally adjusted gross income ([IRC § 170(b)(1)(G)](https://www.law.cornell.edu/uscode/text/26/170)). Gifts to a private nonoperating foundation fall under the 30% limit for cash ([§ 170(b)(1)(B)](https://www.law.cornell.edu/uscode/text/26/170)) and 20% for capital gain property ([§ 170(b)(1)(D)](https://www.law.cornell.edu/uscode/text/26/170)). Appreciated property given to a public charity is limited to 30% ([§ 170(b)(1)(C)](https://www.law.cornell.edu/uscode/text/26/170)). Excess carries forward five years.

A gift of appreciated property to a private nonoperating foundation is deducted at your cost basis, with one exception for listed stock, and that matters more than the limits. The deduction is reduced by the gain ([IRC § 170(e)(1)(B)(ii)](https://www.law.cornell.edu/uscode/text/26/170)). The exception is “qualified appreciated stock”: stock with market quotations readily available on an established securities market, and only up to 10% of a company’s stock counting family gifts ([§ 170(e)(5)](https://www.law.cornell.edu/uscode/text/26/170)). Founder shares, LLC interests, and real estate given to a family foundation are deductible at basis. Given to a DAF, they’re deductible at fair market value, with a qualified appraisal.

Starting in 2026 two federal changes cut the value of an itemized charitable deduction. The first is a floor: itemized charitable gifts count only to the extent they exceed 0.5% of your contribution base (new IRC § 170(b)(1)(I)). It comes from section 70425 of the 2025 tax law, [Pub. L. 119-21](https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm), signed July 4, 2025, one of three changes that apply to taxable years beginning after December 31, 2025. The floor applies first to gifts under the 20% limit, then 30%, and last to 60% cash gifts, and the amount it disallows carries forward only from years in which you also exceed a percentage limit (new § 170(d)(1)(C)). The same section makes the 60% cash limit permanent.

A second change trims what each deducted dollar saves, to about 35 cents for a filer well into the 37% bracket. Section 70111 rewrites § 68. Itemized deductions are reduced by 2/37 of the lesser of your itemized deductions or your taxable income above the start of the 37% bracket. For a filer well into that bracket, each deducted dollar saves 37 cents less 2/37 of 37 cents, which is 35 cents, by Ridley Law’s arithmetic. Section 70424 gives non-itemizers a deduction of up to $1,000, or $2,000 on a joint return, for cash gifts to public charities, and § 170(p) still excludes gifts to set up or add to a donor advised fund ([IRC § 170(p)](https://www.law.cornell.edu/uscode/text/26/170)).

| Gift | Deduction before floor | Less 0.5% floor | Deduction allowed | Federal tax saved at 35 cents per dollar | Why |
| --- | --- | --- | --- | --- | --- |
| Cash or listed stock to a DAF | $1,000,000 | $25,000 | $975,000 | $341,250 | 60% cash / 30% stock limit; deduction at fair market value |
| Listed stock to a private foundation | $1,000,000 | $25,000 | $975,000 | $341,250 | Qualified appreciated stock keeps fair market value (§ 170(e)(5)); 20% limit |
| Closely held stock to a DAF | $1,000,000 | $25,000 | $975,000 | $341,250 | Fair market value, qualified appraisal required; 30% limit |
| Closely held stock to a private foundation | $100,000 | $25,000 | $75,000 | $26,250 | Cut to basis (§ 170(e)(1)(B)(ii)); 20% limit |

California leaves the 0.5% floor and the 2/37 cut off your state return, but it caps cash deductions lower and taxes you at up to 13.3%. The Franchise Tax Board says California doesn’t conform to Pub. L. 119-21 §§ 70424, 70425, or 70111 ([FTB, Summary of Federal Income Tax Changes](https://www.ftb.ca.gov/about-ftb/data-reports-plans/Summary-of-Federal-Income-Tax-Changes/index.html)), so the 0.5% floor and the 2/37 cut stay off your California return. California’s conformity date for 2025 and later years is January 1, 2025 ([R&TC § 17024.5](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17024.5)), and it keeps its own phaseout of itemized deductions ([R&TC § 17077](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17077)). California also limits the deduction for cash gifts to 50% of federal AGI, not 60% ([FTB 2025 Schedule CA (540) instructions](https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html)). With a top rate of 13.3% (12.3% plus the 1% tax on income over $1,000,000, [FTB 2025 rate schedules](https://www.ftb.ca.gov/forms/2025/2025-540-tax-rate-schedules.pdf); [R&TC § 17043](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17043)), giving appreciated stock instead of selling it first matters more here than in most states.

## Giving company stock around a sale

Waiting until the sale is signed can cost the deduction and leave you taxed on the gain. In [Estate of Hoensheid v. Commissioner, T.C. Memo. 2023-34](https://www.courtlistener.com/opinion/9384003/estate-of-scott-m-hoensheid-anne-m-hoensheid-personal-representative-and-anne/), owners gave company stock to a DAF two days before the sale of the company closed. The Tax Court held the sale was virtually certain by then, so the donors were taxed on the gain, and it denied the charitable deduction because the appraisal didn’t meet the qualified appraisal rules. It did not impose a penalty.

So give early, before the deal is locked, and get a qualified appraisal from a qualified appraiser. Match the recipient to the asset, too. Founder shares given to a private foundation are cut to basis by § 170(e)(1)(B)(ii), while listed stock held over a year keeps its fair market value deduction there, up to 10% of the company (§ 170(e)(5)).

## The rules a foundation lives under

A foundation owes 1.39% of its net investment income every year ([IRC § 4940(a)](https://www.law.cornell.edu/uscode/text/26/4940)). Pub. L. 119-21 rewrote the endowment tax on private colleges and universities in § 4968 (§ 70415) but did not amend § 4940, so the foundation rate stays 1.39%. A DAF owes no such tax on the fund. The foundation must also pay out its minimum investment return, which is 5% of its investment assets, net of acquisition debt ([IRC § 4942(e)(1)](https://www.law.cornell.edu/uscode/text/26/4942)). The distributable amount is that return less the foundation’s income and § 4940 taxes (§ 4942(d)), and income still undistributed at the start of the second year after the year it was due draws a 30% tax (§ 4942(a)). A DAF has no payout rule in §§ 4966 or 4967.

The family can’t do business with its own foundation. Sales, leases, loans, services, and transfers of foundation assets between the foundation and a disqualified person are self-dealing ([IRC § 4941(d)(1)](https://www.law.cornell.edu/uscode/text/26/4941)). Disqualified persons include substantial contributors, foundation managers, and their family members ([§ 4946(a)(1)](https://www.law.cornell.edu/uscode/text/26/4946)). The self-dealer owes 10% of the amount involved for each year, and 200% if the act isn’t corrected (§ 4941(a)(1), (b)(1)). The exception is reasonable pay for personal services that are reasonable and necessary to the foundation’s exempt purposes (§ 4941(d)(2)(E)), which is what lets you pay your children a salary from a foundation. In [Thorne v. Commissioner, 99 T.C. 67 (1992)](https://www.courtlistener.com/opinion/4707284/thorne-v-commissioner/), a foundation manager escaped the second-tier taxes for a jeopardizing investment and uncorrected grants because the IRS never asked him to correct them. He was liable for first-tier taxes and penalties on grants he knowingly approved, including grants to trustees’ relatives and his own conference travel.

The foundation also can’t hold or give away freely, and the limits reach the family’s own holdings. A foundation and its disqualified persons together may generally hold no more than 20% of a company’s voting stock, with a 2% de minimis exception ([IRC § 4943(c)(2)](https://www.law.cornell.edu/uscode/text/26/4943)), and excess holdings draw a 10% tax (§ 4943(a)). The same rule applies to a donor advised fund (§ 4943(e)). An investment that jeopardizes the foundation’s exempt purposes draws a 10% tax on the foundation for each year ([IRC § 4944(a)](https://www.law.cornell.edu/uscode/text/26/4944)). Lobbying, election activity, grants to individuals without an IRS-approved procedure, and grants to most non-public charities without expenditure responsibility are taxable expenditures ([IRC § 4945(d)](https://www.law.cornell.edu/uscode/text/26/4945)). Scholarships, prizes and similar grants to individuals are allowed under an approved procedure (§ 4945(g)), while a DAF grant to an individual is a taxable distribution. In [Mannheimer Charitable Trust v. Commissioner, 93 T.C. 35 (1989)](https://www.courtlistener.com/opinion/4706970/mannheimer-charitable-trust-v-commissioner/), a foundation made grants to two other private foundations set up by the same founder, with overlapping managers. The money was spent properly, but the foundation hadn’t exercised expenditure responsibility, so the grants were taxable expenditures. The court rejected “substantial compliance.”

A foundation also gives up privacy. Its annual return, Form 990-PF, is public, and unlike a public charity it can’t withhold the names and addresses of its contributors ([IRC § 6104(b), (d)(3)(A)](https://www.law.cornell.edu/uscode/text/26/6104)). A DAF sponsor reports its DAFs only in the aggregate (IRC § 6033(k)).

## The rules a DAF still has to follow

A DAF can’t be used to pay a pledge, buy gala tickets, or cover tuition. A distribution from a DAF to a natural person, or to anyone for a non-charitable purpose, is a taxable distribution, and the sponsor owes 20% of it ([IRC § 4966(a)(1), (c)(1)](https://www.law.cornell.edu/uscode/text/26/4966)). If a donor or donor advisor recommends a grant that gives them or a related person more than an incidental benefit, the tax is 125% of the benefit ([IRC § 4967(a)(1)](https://www.law.cornell.edu/uscode/text/26/4967)). Any grant, loan, or compensation from a DAF to a donor or donor advisor is an excess benefit transaction ([IRC § 4958(c)(2)](https://www.law.cornell.edu/uscode/text/26/4958)).

The 2023 proposed DAF regulations are still proposed, and taxpayers may rely on them until Treasury finishes. Treasury published them on November 14, 2023 ([88 FR 77922](https://www.federalregister.gov/documents/2023/11/14/2023-24982/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966)), extended comments to February 15, 2024 ([89 FR 1042](https://www.federalregister.gov/documents/2024/01/09/2024-00260/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966)), and scheduled a public hearing for May 6, 2024 ([89 FR 28690](https://www.federalregister.gov/documents/2024/04/19/2024-08419/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966-hearing)). Among other things, they would treat a personal investment advisor who manages both the donor’s own money and the DAF’s assets as a donor-advisor. As of October 9, 2026, the Federal Register shows no final rule or withdrawal under RIN 1545-BI33. The proposal says it would apply to taxable years ending after final regulations are published, and taxpayers may rely on it until then.

## What it takes to set up and run a foundation in California

A foundation takes real setup and upkeep, and a DAF takes an application, so many families start with a DAF. A foundation is a separate legal entity, usually a nonprofit corporation or a trust. It needs governing documents, a board, an exemption application on IRS Form 1023 (the IRS user fee is $600, per the [IRS](https://www.irs.gov/charities-non-profits/form-1023-and-1023-ez-amount-of-user-fee)), California registration within 30 days of its first asset, and an annual Form 990-PF and RRF-1. Add investment management, accounting, and, at $2 million of revenue in a year, an audit. A DAF needs only an application with a sponsor. Sponsors charge administrative and investment fees that vary by sponsor and account size.

A charitable corporation or trustee must register with the Attorney General within 30 days after first receiving property ([Gov. Code § 12585](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12585), with [Attorney General, Initial Registration](https://oag.ca.gov/charities/initial-reg)). After that, the foundation files Form RRF-1 every year with its Form 990-PF, within 4 months and 15 days after year end. Form CT-TR-1 is for charities that don’t file a Form 990 ([Attorney General, Annual Registration Renewal](https://oag.ca.gov/charities/renewals)). A DAF donor doesn’t register. The sponsor does. A registered charity with gross revenue of $2,000,000 or more in a year must have audited financial statements ([Gov. Code § 12586(e)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12586)), and a foundation funded with a large gift in one year can cross that line. California also grants its own exemption to organizations operated exclusively for charitable purposes, and requires that their assets be irrevocably dedicated to those purposes ([R&TC § 23701d](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=23701d)).

Both spouses should sign large gifts to a foundation or DAF. A spouse can’t give away community personal property without the other spouse’s written consent ([Fam. Code § 1100(b)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FAM&sectionNum=1100)).

## Choosing between them

Many families use both: a DAF for routine giving and closely held stock, and a foundation for the program they want their children to run. If the plan also needs a charitable trust, compare a [charitable remainder trust](https://ridleylawoffices.com/charitable-remainder-trust-attorney-california/) and the broader [high-net-worth estate plan](https://ridleylawoffices.com/high-net-worth-estate-planning-california/).

| Question | If yes |
| --- | --- |
| Must family control grants and staff? | Private foundation, accepting the §§ 4941 to 4945 rules |
| Giving closely held or low-basis stock? | DAF or public charity, which keeps the fair market value deduction |
| Want donors and grants kept private? | Donor advised fund; no Form 990-PF |
| Need grants to individuals? | Foundation with an IRS-approved procedure (§ 4945(g)) |
| None of the above | A DAF is usually simpler and cheaper |

## Working with Ridley Law

I work alongside your CPA and, where the matter calls for it, co-counsel. Work at this level is built for each family and quoted in writing before any drafting starts.

The first call is free and runs 30 minutes, by phone or Zoom. [Book my 30-minute call](https://ridley.click/eric-30) or call 805-244-5291.

## Frequently asked questions

### Is a donor advised fund better than a private foundation?

Often, yes, for giving that doesn’t need family control. A DAF gets higher deduction limits, deducts appreciated non-public stock at fair market value, has no payout rule or investment income tax, and keeps your giving private. A foundation is better when family control, staff, or grants to individuals matter more than those advantages.

### How much money do you need to start a private foundation?

The fixed costs decide it more than any rule. Legal setup, the $600 IRS filing fee, annual 990-PF and California filings, and accounting make a foundation hard to justify for small amounts. That’s a judgment call, and it’s why many families start with a DAF.

### Does a private foundation have to give away 5% a year?

Yes, roughly. The minimum investment return is 5% of investment assets, and the required distribution is that amount less the foundation’s income taxes and its 1.39% investment income tax (IRC § 4942). Income left undistributed into the second following year draws a 30% tax.

### Can I pay my children a salary from my foundation?

Only reasonable pay for personal services that are reasonable and necessary to the foundation’s exempt purposes. Paying a disqualified person is otherwise self-dealing (IRC § 4941(d)(2)(E)). A DAF can’t pay a donor or the donor’s family at all (IRC § 4958(c)(2)).

### Did the 2025 tax law raise the private foundation excise tax?

No. Pub. L. 119-21 changed the tax on large college and university endowments in § 4968, but it did not amend § 4940. The private foundation rate is still 1.39% of net investment income.

### Are the IRS donor advised fund regulations final?

No. They were proposed November 14, 2023 (88 FR 77922). As of October 9, 2026, the Federal Register shows no final rule. Taxpayers may rely on the proposed rules until final rules are published.

### Can I move my private foundation into a donor advised fund?

Often, yes. A foundation’s grant to a public charity described in § 509(a)(1) isn’t a taxable expenditure (IRC § 4945(d)(4)(A)), so confirm the sponsor’s status first. Ending the foundation is a separate step: § 507 generally requires notice to the IRS, and the Attorney General’s Registry has its own dissolution process. Plan both before moving money.

This page is general information about California and federal law as of its update date. It isn’t legal, tax, or investment advice for your situation, and reading it doesn’t create an attorney-client relationship.

**Related reading:** [donor advised funds: what Reddit gets right and wrong](https://ridleylawoffices.com/guides/donor-advised-fund-reddit/); [charitable remainder trusts in California](https://ridleylawoffices.com/charitable-remainder-trust-attorney-california/); [charitable remainder trusts on Reddit](https://ridleylawoffices.com/guides/charitable-remainder-trust-reddit/); [charitable remainder trust (glossary)](https://ridleylawoffices.com/estate-planning-glossary-california/charitable-remainder-trust/); [charitable remainder unitrusts](https://ridleylawoffices.com/how-a-charitable-remainder-unitrust-crut-can-pay-you-for-life-and-support-a-cause-you-love/); [charitable giving in an estate plan](https://ridleylawoffices.com/7-key-steps-charitable-giving-in-estate-plans/); [estate planning strategies compared](https://ridleylawoffices.com/estate-planning-strategies-compared/); [QSBS and California](https://ridleylawoffices.com/qsbs-section-1202-california/).

Sources

- [U.S. Congress, Pub. L. 119-21 (enrolled text), §§ 70111, 70415, 70424, 70425](https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm) (2025-07-04)
- [U.S. Congress (via Cornell LII), 26 U.S.C. §§ 68, 170, 507, 509, 4940, 4941, 4942, 4943, 4944, 4945, 4946, 4958, 4966, 4967, 6033, 6104](https://www.law.cornell.edu/uscode/text/26/170) (current)
- [Treasury and IRS, Proposed regulations, Taxes on Taxable Distributions From Donor Advised Funds Under Section 4966, 88 FR 77922](https://www.federalregister.gov/documents/2023/11/14/2023-24982/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966) (2023-11-14)
- [Treasury and IRS, Extension of comment period, 89 FR 1042](https://www.federalregister.gov/documents/2024/01/09/2024-00260/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966) (2024-01-09)
- [Treasury and IRS, Notice of public hearing, 89 FR 28690](https://www.federalregister.gov/documents/2024/04/19/2024-08419/taxes-on-taxable-distributions-from-donor-advised-funds-under-section-4966-hearing) (2024-04-19)
- [Federal Register, documents under RIN 1545-BI33 (no final rule listed)](https://www.federalregister.gov/api/v1/documents.json?conditions%5Bregulation_id_number%5D=1545-BI33) (accessed 2026-10-09)
- [IRS, Form 1023 and 1023-EZ: Amount of user fee](https://www.irs.gov/charities-non-profits/form-1023-and-1023-ez-amount-of-user-fee) (accessed 2026-10-09)
- [California Legislature, Gov. Code §§ 12585, 12586; Fam. Code § 1100](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12585) (current)
- [California Legislature, Rev. & Tax. Code §§ 17024.5, 17043, 17077, 23701d](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=23701d) (current)
- [California Attorney General, Registry of Charities and Fundraisers](https://oag.ca.gov/charities) (accessed 2026-10-09)
- [California Attorney General, Registry of Charities and Fundraisers, Initial Registration](https://oag.ca.gov/charities/initial-reg) (accessed 2026-10-09)
- [California Attorney General, Annual Registration Renewal (Forms RRF-1, CT-TR-1)](https://oag.ca.gov/charities/renewals) (accessed 2026-10-09)
- [Franchise Tax Board, Summary of Federal Income Tax Changes (Pub. L. 119-21)](https://www.ftb.ca.gov/about-ftb/data-reports-plans/Summary-of-Federal-Income-Tax-Changes/index.html) (accessed 2026-10-09)
- [Franchise Tax Board, 2025 Schedule CA (540) instructions](https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html) (2025)
- [Franchise Tax Board, 2025 California tax rate schedules](https://www.ftb.ca.gov/forms/2025/2025-540-tax-rate-schedules.pdf) (2025)
- [U.S. Court of Appeals, 9th Cir., Pinkert v. Schwab Charitable Fund, 48 F.4th 1051, No. 21-16299 (court’s slip opinion)](https://cdn.ca9.uscourts.gov/datastore/opinions/2022/09/14/21-16299.pdf) (2022-09-14)
- [U.S. District Court, N.D. Cal., Fairbairn v. Fidelity Investments Charitable Gift Fund, No. 18-cv-04881-JSC, opinion following bench trial](https://www.courtlistener.com/opinion/9600254/fairbairn-v-fidelity-investments-charitable-gift-fund/) (2021-02-26)
- [U.S. Tax Court, Estate of Hoensheid v. Commissioner, T.C. Memo. 2023-34](https://www.courtlistener.com/opinion/9384003/estate-of-scott-m-hoensheid-anne-m-hoensheid-personal-representative-and-anne/) (2023-03-15)
- [U.S. Tax Court, Mannheimer Charitable Trust v. Commissioner, 93 T.C. 35](https://www.courtlistener.com/opinion/4706970/mannheimer-charitable-trust-v-commissioner/) (1989-07-12)
- [U.S. Tax Court, Thorne v. Commissioner, 99 T.C. 67](https://www.courtlistener.com/opinion/4707284/thorne-v-commissioner/) (1992-07-20)