The document outlines a proposal to create a Type I supporting organization (SO) under National Philanthropic Trust (NPT), which would be a separate legal entity from the supported public 501(c)(3) organization. The memo details the advantages of such a structure, including tax benefits, donor participation, investment attributes, and governance structure. It also discusses the regulatory constraints and the management agreement between NPT and the supporting organization.
documents/EFTA00314876.pdf
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