•Charities may make gifts to QDs
•Charities cannot give money or other resources to individuals or other organizations that are not QDs
•For example - charity working with a for-profit or NPO to do a joint program
–Is the charity providing resources for
the benefit of the NPO or for-profit?
–Is the charity getting fair market value (“FMV”) compensation for its resources?
–Is the charity accomplishing its charitable objectives as part of the program?