Timeline of laws, court and IRS rulings, organizational foundings and developmental events that have helped shape fiscal sponsorship:

1883

Russell vs. Allen. U.S. Supreme Court determines that federal tax law requires the beneficiaries of a charitable contribution to be indefinite.

1954

Internal Revenue Code 501(c)(3) enacted, providing the modern basis for charitable, nonprofit, religious and educational organizations to be tax-exempt.

1959

Massachusetts Health Research Institute (now Third Sector New England): incorporates and takes on its first fiscal sponsorship, the earliest fiscal sponsor in the directory, the anchor for East Coast fiscal sponsors, a pioneer in the field.

1963

IRS issues ruling which declares that when charity acts as a conduit or establishes a pass-through arrangement to receive a donation earmarked for a noncharity, that arrangement will result in loss of tax deduction for the donor (Revenue Ruling 63-252).

1966

IRS Revenue Ruling 66-79 describes how a U.S. charity can exercise “discretion and control” over funds solicited for and regranted to a foreign charity for a specific project.

1969

Congress amends Internal Revenue Code, dividing 501(c)(3) organizations into public charities and private foundations, causing public charities to become magnets for sponsored projects.

1973

Tom Silk opens a law practice in San Francisco, develops early theories of proper fiscal sponsorship under federal tax law by providing advice and representation in IRS controversies: his firm grew into Silk, Adler & Colvin.

1987

National Foundation vs. U.S. Court of Claims case approves a prototype of public charity that houses multiple donor-advised funds and sponsored projects. The organization splits into three entities that still operate: National Heritage Foundation, Congressional District Programs, and Charity Admin Inc. National Heritage Foundation and Congressional District Programs are included in the directory.

1989

“Use of Fiscal Agent: A Trap for the Unwary,” essay by John Edie, published by the Council on Foundations. Cautionary tale at a time of growing interest in fiscal sponsorship.

IRS issues technical advice memo after a “fiscal agent” almost lost its 501(c)(3) exemption because of one of its sponsored projects’ activities related to the 1984 presidential campaign.

1991

Series of meetings to collect and share information on sponsorship practices leads to grant support from the San Francisco and Wallace A. Gerbode foundations for a definitive book on fiscal sponsorship.

1993

Attorney Greg Colvin’s Fiscal Sponsorship: 6 Ways to Do It Right first edition published by San Francisco Study Center.

1994

IRS Continuing Professional Education textbook states there is “nothing inherently wrong with fiscal sponsorship …,” not exactly a ringing endorsement but puts IRS on the record.

1996

Free-standing, multipurpose fiscal sponsor corporations established: Tides Center, Community Partners (Los Angeles), and Community Initiatives Fund of The San Francisco Foundation.

2002

Fractured Atlas becomes first fiscal sponsor to do almost all of its business online.

2005 February

W.K. Kellogg Foundation awards $4.07 million grant to Tides Center to expand its fiscal sponsorship capability.

December

Fiscal Sponsorship: 6 Ways to Do It Right, second edition published.

2006 February

Fiscalsponsorship.com, Website of Greg Colvin, attorney and author of Fiscal Sponsorship: 6 Ways to Do It Right, is launched as a companion resource to the book

April

The Schwab Fund for Charitable Giving awards $50,000 grant to San Francisco Study Center to create online directory of fiscal sponsors.

May

National Network of Fiscal Sponsors launches field scan to gather first comprehensive data on fiscal sponsors.

August

Congress passes Pension Protection Act, with amendments to Internal Revenue Code affecting donor-advised funds and, indirectly, some fiscally sponsored projects.

2007 October

National Network of Fiscal Sponsors Inaugural Gathering in Los Angeles.
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