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professional rodeos are not qualified amateur sports organizations (Priv. Ltr. Ruls. 201933016, 201706019).

§ 11.8 DONOR‐ADVISED FUNDS

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(c) Portrait of Donor‐Advised Fund Universe

An analysis of donor‐advised funds, examining data for 2014–2018 from 989 sponsoring organizations, was issued in late 2019.^96.1 A letter introducing this report states that “[o]ver the past decade, donor‐advised funds have experienced tremendous growth.” The letter highlights three extraordinary developments. One is that “grantmaking from donor‐advised funds to qualified charities has nearly doubled in the past five years.” Grants from DAFs in 2018 totaled $23.42 billion. Two, there has been an 86 percent increase in contributions to the funds over the past five years. The number for 2018 is $37.12 billion. Three, for the second year in a row, “there was growth above 50 percent in the number of new donor‐advised fund accounts.”

      Total estimated charitable contributions in the United States in 2018 were $427.71 billion (see the September 2019 issue). Of this amount, $292.09 billion came from individuals (68 percent). Thus, donors to donor‐advised funds accounted for 12.7 percent of individual giving. Contributions to DAFs expressed as a percentage of total annual individual giving have steadily increased during 2010–2018.

There were an estimated 728,563 donor‐advised funds in 2018, compared to about 80,000 private foundations (not including corporate foundations). Assets in donor‐advised funds in 2018 had an estimated value of $121.42 billion, while at the same time assets in private foundations had an estimated value of $872.65 billion. Yet grants from donor‐advised funds in 2018 (as noted, $23.42 billion) equated to just over 43 percent of the estimated $54.03 billion granted by private foundations during the year.

      Contributions to donor‐advised funds in 2018 increased by 20.1 percent in relation to the total for 2017. Grants from these funds to charitable entities amounted to an 18.9 percent increase from the total for 2017. Assets under management in donor‐advised funds increased by 8.3 percent compared to the value in 2017. The number of these funds “increased sharply,” rising by 55.2 percent in 2018. The payout rate for donor‐advised funds in 2018 was 20.9 percent.

      The average size of a donor‐advised fund in 2018 is estimated to be $166,653. This is a 30.2 percent decrease compared to the 2017 number ($238,857). The NPT report states that the “emergence of workplace giving donor‐advised fund accounts and sponsoring organizations that have no or low contribution minimums will continue to drive down the average donor‐advised fund size.”

      The NPT report includes a comparison of donor‐advised funds from the standpoint of type of sponsoring organization. Noting that there are about 1.33 million “registered” public charities in the United States, the charities tracked in the report comprise less than 1/10th of 1 percent of these organizations. The report offers this overview: (1) the number of donor‐advised funds sponsored by national charities exceeds the number of accounts at the other two types of sponsoring organizations combined, (2) the national charities have higher aggregate charitable asset values and distribute more grant dollars, (3) the average donor‐advised fund asset size at community foundations is higher than at the other two types of sponsoring organizations, and (4) single‐issue charity sponsors have the highest payout rate.

      The NPT report includes data from 54 national charities. These sponsoring organizations had, in 2018, combined 593,356 donor‐advised funds (an increase of 75 percent compared to 2017) with total assets of $72.35 billion. The compound annual growth rate of donor‐advised funds in this category is 46.4 percent (2014–2018). Contributions to these donor‐advised funds reached $23.38 billion in 2018 (a 24.1 percent increase over 2017). Grants from these funds in 2018 totaled $13.1 billion (a 26.8 percent increase). Charitable assets in these funds had a value of $72.35 billion (a 22.6 percent increase). The average fund size of these funds in 2018 is estimated to be $121,937 (a 30 percent decline). The total payout rate from these funds in 2018 is 22.2 percent (down from 23 percent).

      The report analyzes data from 603 community foundations. These sponsoring organizations had, in 2018, combined 77,234 donor‐advised funds (a 2.8 percent increase) and total assets of $33.87 billion. The compound annual growth rate of these funds is 3.9 percent (2014–2018). Contributions to donor‐advised funds at community foundations in 2018 totaled $8.38 billion (a 15.4 percent increase). Grants from these funds amounted to $6.59 billion (a 10.2 percent increase). Charitable assets in these funds in 2018 were $33.87 billion (a 14.9 percent decrease). The average account size was $438,561 (a 17.2 percent decrease). The total payout rate from these funds in 2018 is 24.8 percent (an increase from 20 percent).

The 332 single‐issue charities reflected in this report held, in 2018, 57,973 donor‐advised funds (a 5.1 percent increase), with charitable assets totaling $15.19 billion. The compound annual growth rate (2014–2018) was 5.9 percent. Contributions to these funds totaled $5.36 billion (an 11.7 percent increase). Grants from these funds were $3.73 billion (a 10.3 percent increase). Charitable assets amounted to $15.19 billion (an increase of 14.5 percent). The average account size of these funds in 2018 was $262,075 (a 9 percent increase). The payout rate from these funds was 28.2 percent (a drop from the 2017 rate of 29.6 percent).

The NPT expects that grantmaking from donor‐advised funds “will continue to grow at a consistently high rate.” It is noted that, in 2018, the growth in contributions to donor‐advised funds outpaced the growth of grants from these funds, reversing a four‐year trend. Speculation is that bunching is a major factor in this regard. Another observation is that “emerging models” for donor‐advised funds, such as workplace giving using them and low‐ or no‐minimum donor‐advised fund accounts “will play a significant role” as to the number of individual accounts and consequently “drive down the average donor‐advised fund account size.”^96.2

§ 11.9 ENDOWMENT FUNDS

      (b) College and University Endowment Tax

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      Also Reg. § 53.4968‐1(a).

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      IRC § 4968(b)(1); Reg. § 53.4968‐1(b)(1).

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      ; Reg. § 53.4968‐3(a)(1).

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The number of students of an institution (including for purposes of determining the number of students at a particular location) is based on the daily average number of full‐time students attending the institution (with part‐time students taken into account on a full‐time student equivalent basis).^105.1

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(ii) Final Regulations. The Department of the Treasury and the IRS issued

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