Charitable Deduction for Association Foundations

Gifts to an association's affiliated 501(c)(3) foundation should keep the same charitable-deduction treatment as gifts to any other public charity, regardless of the fact that the foundation shares a name, a building, or a board relationship with a 501(c)(6) trade association. NANA is watching this issue on behalf of the NANA Foundation, its own affiliated 501(c)(3), which funds CAE exam-fee scholarships and institutional grants to member associations. Samuel Heathcote, the Foundation's executive director, says the recurring concern in Washington is that a (c)(3) affiliated with a (c)(6) will eventually draw scrutiny simply for the affiliation, even where the foundation's giving is entirely separate from the trade association's own advocacy and membership activity. No specific bill or rule has moved on this yet, which is why the file sits at monitoring status, but NANA is building its record now rather than waiting for a proposal to force a reaction.

A number of NANA's larger member associations operate their own affiliated foundations, funding scholarships, research grants, or disaster relief for their sector, and all of them depend on individual donors being able to claim the same charitable deduction they would for a gift to an unaffiliated charity. The NANA Foundation's own scholarship program is a direct example of what's at stake: it funded 18 CAE exam-fee scholars in 2024, 21 in 2025, and 24 in 2026, a cohort that grows each year in part because individual donors treat their gifts as fully deductible. Any narrowing of that treatment for foundations affiliated with a trade association would shrink the donor pool precisely where it funds the most member-facing work — scholarships and grants that reach individual professionals and small member organizations, not the trade association's own operations.

NANA is asking Congress and the IRS to confirm, rather than narrow, that an affiliated 501(c)(3) foundation's charitable-deduction treatment does not depend on its relationship to a 501(c)(6) parent, so long as the foundation's own activities meet the ordinary public-charity test. Member associations that operate an affiliated foundation are asked to tell NANA's public policy team now, so the file reflects how many associations and how much donor giving is actually affected, rather than an estimate built around NANA's own foundation alone. Foundations that track an annual individual-donor total are asked to share it for the same reason. The CAE Scholarship Application Guide describes how the NANA Foundation's own scholarship program is funded, as a working example other member foundations can point to.