I operate an existing 501(c)(3) organization and am interested in launching an additional one. Can I accept donations to the existing organization to be used by the new one before the new one obtains its own recognition of exemption? What should be my concerns?
Assuming that this project is approved by your Board and is not a frolic of your own, it is not at all unusual for one charity to act as a fiscal sponsor for another organization that does charitable things but has not received recognition of exemption. You want to be sure that supporting the type of activities being conducted by the new group is within the charitable purpose of the currently exempt organization. You also want to be sure that the contributions are not earmarked for the new organization (although they may be earmarked for the kind of program the new organization will conduct). The gifts would not be automatic qualifying distributions for a private foundation if earmarked for the new organization and might not be deductible by individuals if the organization never qualifies as a charity. Primarily you want to be sure that the existing organization controls the use of the contributions and whether or not they are forwarded to the new entity. (See Ready Reference Page: “Charities Must Take Care in Serving as Conduits.”)