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Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 -> 59,740; repo total 105,704 records. Deterministic (byte-identical rerun, verified on Title 42's 8,356 sections); make check green. make legal-us-code default now covers every title. Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>
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| LegalText | 26 U.S.C. § 4967 | Taxes on prohibited benefits | us | united_states_code | code_section | 26 | INTERNAL REVENUE CODE | 42 | PRIVATE FOUNDATIONS; AND CERTAIN OTHER TAX-EXEMPT ORGANIZATIONS | 4967 | 26 U.S.C. § 4967 | current | 119-100 | 2026-06-26 | official | https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip | /us/usc/t26/s4967 | data/legal/raw/us/code/title-26/usc26.xml | 2c7e0d5475cd58d7ed8a102b6d31fe21667e63e3c85dcf06d3a7837f272f6e64 | a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4 | f6c983b460e115ae8d01c4b0f142b7c0cc1432aa97cc3c2bbc83337abedb7b54 | 2026-07-04 | official |
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26 U.S.C. § 4967 - Taxes on prohibited benefits
Text
(a) Imposition of taxes (1) On the donor, donor advisor, or related person There is hereby imposed on the advice of any person described in subsection (d) to have a sponsoring organization make a distribution from a donor advised fund which results in such person or any other person described in subsection (d) receiving, directly or indirectly, a more than incidental benefit as a result of such distribution, a tax equal to 125 percent of such benefit. The tax imposed by this paragraph shall be paid by any person described in subsection (d) who advises as to the distribution or who receives such a benefit as a result of the distribution.
(2) On the fund management There is hereby imposed on the agreement of any fund manager to the making of a distribution, knowing that such distribution would confer a benefit described in paragraph (1), a tax equal to 10 percent of the amount of such benefit. The tax imposed by this paragraph shall be paid by any fund manager who agreed to the making of the distribution.
(b) Exception No tax shall be imposed under this section with respect to any distribution if a tax has been imposed with respect to such distribution under section 4958.
(c) Special rules For purposes of subsection (a)—
(1) Joint and several liability If more than one person is liable under paragraph (1) or (2) of subsection (a) with respect to a distribution described in subsection (a), all such persons shall be jointly and severally liable under such paragraph with respect to such distribution.
(2) Limit for management With respect to any one distribution described in subsection (a), the maximum amount of the tax imposed by subsection (a)(2) shall not exceed $10,000.
(d) Person described A person is described in this subsection if such person is described in section 4958(f)(7) with respect to a donor advised fund.
(Added Pub. L. 109–280, title XII, § 1231(a), Aug. 17, 2006, 120 Stat. 1097.)
Notes
Statutory Notes and Related Subsidiaries
Effective DateSection applicable to taxable years beginning after Aug. 17, 2006, see section 1231(c) of Pub. L. 109–280, set out as an Effective Date of 2006 Amendment note under section 4963 of this title.