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I think I screwed up. It has been a while, but it looks like I misread Part II, Section B, Line 10 as $70 million, not $70,000. Let me check the previous year

by baking 3y ago

I think I screwed up. It has been a while, but it looks like I misread Part II, Section B, Line 10 as $70 million, not $70,000. Let me check the previous years to see if I'm thinking of something else. Thanks for double-checking this. I know they got $20 million from Open Philanthropy which qualifies as public support, so I am still wondering about the other $70 million, but it is not the smoking gun that I thought it was. It has to be made up of donations from individuals under $2.6 million or from other public charities, but not private foundations.

mikeyouse 3y ago
Most rich people setup DAFs alongside their family foundations so that they can make large contributions to this type of org. without triggering disclosure or private foundation tests -- so e.g. Musk will create a DAF at Fidelity Charitable and give them $100M and collect the associated tax break in year 1 -- he can then direct Fidelity to grant $20M/year to OpenAI which will show up as Public Support since it's coming from another nonprofit entity and Fidelity maintains ultimate discretion over the funds. Edit - Got curious and sure enough - this is the 28,000 page 990 filing for Fidelity Charitable: https://apps.irs.gov/pub/epostcard/cor/110303001_202006_990_2021052818214346.pdf https://apps.irs.gov/pub/epostcard/cor/110303001_202006_990_... On page 205 there's a $3.5M donation to OpenAI from 2019. Likewise here for SVCF on page 237 (https://apps.irs.gov/pub/epostcard/cor/205205488_201912_990_2021033117841113.pdf https://apps.irs.gov/pub/epostcard/cor/205205488_201912_990_...) - there's a $30M donation to OpenAI in 2019.
- trogdor 3y ago
  I am an investigative reporter, and I approve of your research tenacity! Nice :)
- baking 3y ago
  Nice work. The IRS proposed regulations in 2017 that contributions from DAFs should be treated as if they came directly from an individual donor, but they are still waiting on final regulations. https://www.irs.gov/pub/irs-drop/n-17-73.pdf https://www.irs.gov/pub/irs-drop/n-17-73.pdf https://taxnews.ey.com/news/2023-1927-irs-releases-proposed-regulations-for-donor-advised-funds https://taxnews.ey.com/news/2023-1927-irs-releases-proposed-...
- baking 3y ago
  Reid Hoffman gave $10 million through his private foundation, Aphorism Foundation, in 2017 and 2018: https://apps.irs.gov/pub/epostcard/cor/464347021_201712_990PF_2019020216058359.pdf https://apps.irs.gov/pub/epostcard/cor/464347021_201712_990P... https://apps.irs.gov/pub/epostcard/cor/464347021_201812_990PF_2019123116986121.pdf https://apps.irs.gov/pub/epostcard/cor/464347021_201812_990P... Since private foundations aren't public charities, they don't have the pass-through protection of donor-advised funds, so this should have been excluded from the public support total because it is more than 2% of the total support. Also, this reporter did some additional legwork earlier in 2023: https://techcrunch.com/2023/05/17/elon-musk-used-to-say-he-put-100m-in-openai-but-now-its-50m-here-are-the-receipts/ https://techcrunch.com/2023/05/17/elon-musk-used-to-say-he-p...

by baking 3y ago

mikeyouse 3y ago

Most rich people setup DAFs alongside their family foundations so that they can make large contributions to this type of org. without triggering disclosure or private foundation tests -- so e.g. Musk will create a DAF at Fidelity Charitable and give them $100M and collect the associated tax break in year 1 -- he can then direct Fidelity to grant $20M/year to OpenAI which will show up as Public Support since it's coming from another nonprofit entity and Fidelity maintains ultimate discretion over the funds. Edit - Got curious and sure enough - this is the 28,000 page 990 filing for Fidelity Charitable: https://apps.irs.gov/pub/epostcard/cor/110303001_202006_990_2021052818214346.pdf https://apps.irs.gov/pub/epostcard/cor/110303001_202006_990_... On page 205 there's a $3.5M donation to OpenAI from 2019. Likewise here for SVCF on page 237 (https://apps.irs.gov/pub/epostcard/cor/205205488_201912_990_2021033117841113.pdf https://apps.irs.gov/pub/epostcard/cor/205205488_201912_990_...) - there's a $30M donation to OpenAI in 2019.

trogdor 3y ago
I am an investigative reporter, and I approve of your research tenacity! Nice :)
baking 3y ago
Nice work. The IRS proposed regulations in 2017 that contributions from DAFs should be treated as if they came directly from an individual donor, but they are still waiting on final regulations. https://www.irs.gov/pub/irs-drop/n-17-73.pdf https://www.irs.gov/pub/irs-drop/n-17-73.pdf https://taxnews.ey.com/news/2023-1927-irs-releases-proposed-regulations-for-donor-advised-funds https://taxnews.ey.com/news/2023-1927-irs-releases-proposed-...
baking 3y ago
Reid Hoffman gave $10 million through his private foundation, Aphorism Foundation, in 2017 and 2018: https://apps.irs.gov/pub/epostcard/cor/464347021_201712_990PF_2019020216058359.pdf https://apps.irs.gov/pub/epostcard/cor/464347021_201712_990P... https://apps.irs.gov/pub/epostcard/cor/464347021_201812_990PF_2019123116986121.pdf https://apps.irs.gov/pub/epostcard/cor/464347021_201812_990P... Since private foundations aren't public charities, they don't have the pass-through protection of donor-advised funds, so this should have been excluded from the public support total because it is more than 2% of the total support. Also, this reporter did some additional legwork earlier in 2023: https://techcrunch.com/2023/05/17/elon-musk-used-to-say-he-put-100m-in-openai-but-now-its-50m-here-are-the-receipts/ https://techcrunch.com/2023/05/17/elon-musk-used-to-say-he-p...