Please know that, although our goal is to service your grant or scholarship (“donor-advised fund”), we feel a responsibility to inform you that IRS tax law ultimately permits us to use your donation at our discretion.

Also, GTP does not permit donors to use funds to serve the donor’s private interests (e.g., to allow the donor to attend retreats, conferences, or seminars; to research investment opportunities; to save for retirement; to provide scholarships to the donor’s family members; to be paid “administrative,” “fundraising,” and “consulting” expenses; and to pay the donor’s children for performing charitable work). GTP is not designed to “warehouse wealth” nor does GTP allow donors to “contribute” property and cash to their foundations, control the investment of those resources, and then allegedly have the income and appreciation on that corpus accrue or be realized tax-free.

How we handle “insiders”

If you are an “insider”, we will move your donation to another fund. You may be an “insider” if you are one or more of the following:

  • the person sponsored in this grant
  • a family member of the person sponsored in this grant
  • an employee of the company sponsored in this grant
  • the company sponsored in this grant
  • a company that may receive payment for expenses covered by this grant from an individual / team sponsored by this grant
  • a board advisor on the voting committee for this grant or scholarship
  • a person who may directly or indirectly control distributions to a supported organization of a Type I, Type II, or functionally integrated Type II IRC 509(a)(3) Supporting Organization that this donation is intended for
  • another “insider”

Donations from those on the SDN List are prohibited

The Office of Foreign Assets Control (“OFAC”) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.

Unless otherwise authorized or exempt, transactions by U.S. persons, or in or involving the United States, are prohibited if they involve transferring, paying, exporting, withdrawing, or otherwise dealing in the property or interests in property of an entity or individual listed on the SDN List.

The fines for violations can be substantial. Depending on the program, criminal penalties for willful violations can include fines ranging up to $20 million and imprisonment of up to 30 years. Civil penalties for violations of the Trading With the Enemy Act can range up to $65,000 for each violation. Civil penalties for violations of the International Emergency Economic Powers Act can range up to $250,000 or twice the amount of the underlying transaction for each violation. Civil penalties for violations of the Foreign Narcotics Kingpin Designation Act can range up to $1,075,000 for each violation.