What is the maximum contribution as a percentage of total support that an individual can give without tipping a 501(3)(c) public charity into being declared a private foundation?
It must be nice to have such concerns. The principles are clear but the precise answer isn’t easy. If you are not a church, school, or hospital (which are automatically deemed to be public charities) or a supporting organization, you have to meet a public support test based on your total support and the various sources of income over a moving five-year period. Although the basic requirement is to have one-third public support over the period, for those organizations qualifying on the basis of contributions (and not counting fees from charitable services), the percentage can dip as low as 10% under the “facts and circumstances” test. Therefore, depending on how the rest of your support is diversified, a single donor might be able to give up to 66% of all support over the five years without going into the facts and circumstances test and might be able to give nearly 90% of the total support under the facts and circumstances test without tipping the organization. Plug your actual numbers into Schedule A of the Form 990 tax information return and you can figure out the approximate size of the gift that will cause you to tip. (See Ready Reference Pages: “Calculating Public Support”)
The bottom line generally is: take the money and figure out how to deal with it later.
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