| Conduct Programmatic Activities? |
No |
Yes, to carry out exempt purposes. |
Yes, to carry out exempt purposes and satisfy IRS POF tests. |
Not typically, but may do so. |
| Earned Income |
Not applicable |
Yes. Many public charities will have earned income. Some rely heavily or even primarily on this type of income to qualify for public charity status (e.g. ticket sales at performing arts organizations). |
Yes. POFs may have earned income. |
Not typically but not prohibited. |
| Foreign Activities |
DAFs do not carry on activities. Grants to foreign charities may be possible via equivalency determination. |
Yes. PCs may engage in foreign activities (including grantmaking) that further their exempt purposes, subject to OFAC (Office of Foreign Assets Control) regulations. |
Yes. POFs may engage in foreign activities that further their exempt purposes, subject to OFAC regulations. Grants must meet IRS requirements for equivalency determination or expenditure responsibility. |
Yes. POFs may engage in foreign activities that further their exempt purposes, subject to OFAC regulations. Grants must meet IRS requirements for equivalency determination or expenditure responsibility. |
| Grantmaking |
Account holder makes recommendations for grants. Generally, must make grants to existing 501(c)(3) public charities (not private foundations) |
May do so but not usually a large part of total program activity. |
May do so but must make sure expenditures on programmatic activities large enough to satisfy IRS POF tests. |
Yes. Typically grants made to U.S.-based 501(c)(3) public charities but may grant to foreign charities or individuals under certain circumstances. |
| Scholarships and Individual Grants |
No |
May make scholarships/grants to individuals; IRS pre-approval not required |
May make scholarships/grants to individuals; IRS pre-approval is required |
May make scholarships/grants to individuals; IRS pre-approval is required |
| Fundraising |
Not applicable |
Yes, many public charities rely heavily on fundraising from the general public and must raise funds from enough diverse sources to qualify as a public charity. |
No, but not restricted from doing so. Most private operating foundations are funded by a few (often related) individuals. |
No, but not restricted from doing so. Most private foundations are funded by a few (often related) individuals. |
