26 Apr '15, 6pm
Bjorn Lomborg's Copenhagen Consensus Center - Real Charity Or "Foreign Conduit"?
“Rev. Rul. 63-252, in applying this principle to transfers of United States- solicited contributions from domestic to foreign organizations, concludes: … 'Moreover, it seems clear that the requirements of section 170(c)(2)(A) of the Code would be nullified if contributions inevitably committed to a foreign organization were held to be deductible solely because, in the course of transmittal to a foreign organization, they came to rest momentarily in a qualifying domestic organization. In such case the domestic organization is only nominally the donee; the real donee is the ultimate foreign recipient.' Rev. Rul. 63-252 then sets forth five examples of this point, each expressing a variation on the theme: (1) A mere conduit entity formed by the beneficiary foreign organization in order to tap into United States resources; “