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Sustainable Philanthropy 


Sustainable Philanthropy emphasizes practices, attitudes, and collaborations that foster equitable, resilient, stable, scalable, and compliant Donor, Exempt Organization, and Stakeholder interactions that give birth to perpetual giving, perpetual operations, and perpetual benefits.

This and the linked pages address the needs of:


  • Donors, to facilitate decisions on their path to Sustainable Philanthropy.

  • Exempt Organizations, their Boards of Directors, Executives, Employees, and the Volunteers who nurture their Donors and provide Public Benefits to their Stakeholders and Constituents.

  • Non-Profit Advisors – the Accountants, Attorneys, Financial and Insurance Advisors, Governance Consultants and other professionals who serve the Sustainable Philanthropic community’s needs.

  • Public Policy Makers and Gatekeepers – In the hope that we shed light on the consequences of your regulatory and legislative actions.

Our goal is to produce a comprehensive body of authoritative and reliable materials viewed from the perspective of both Donors and Exempt Organizations. These materials are divided between a, more-or-less, linear main body narrative,  and a supporting cast of Technical and Procedural Notes.

The main body narrative provides an overview and introduction to the installment topic: i.e., What the topic involves, where it fits in the philanthropic firmament, how to interpret it, information sources to facilitate interpretation, further study, and action, and digressions about its origin, purpose, and history. To the extent possible, the main body of the treatise is non-technical and provides general coverage of the most likely scenarios Donors, Organizations (and their personnel), and Advisors encounter.

Technical and Procedural Notes aim at users with a deep-seated need for sophisticated analysis. Technical and Procedural Notes address topics at a foundational level, dissecting rules, vocabulary, precedents, analytics, and exceptions at a level that addresses the needs of representatives who make and effectuate strategic decisions or advise those who make them. Technical and Procedural Notes “read like an operations management, tax, or accounting textbook,” because that is exactly what they are intended to be! Note, however, that they are not a substitute for well-grounded professional input!

Note to our fellows and colleagues: We welcome your feedback, constructive comments, and questions... and we will publish them and credit you for them if appropriate. We sometimes miss the obvious, so your feedback helps remedy that. We view our colleagues as collaborators - not competition. Feel free to use any of our library materials in your own practice - just give us credit (where credit is appropriate) and don't re-publish them without our permission and acknowledgement (that could get nasty).

With that as prelude:

Sustainable Philanthropy - Outline, Project Parameters, and Links

Donor Perspectives

Sustainable Philanthropy


Philanthropic Style and Avenues

  • Direct or Indirect; Choice of Avenues

  • Public, Private, DAF, Operational, Supporting Organizations

  • What to Give

  • How Much to Give

  • When To Give

    • Intervivos or Testamentary

    • Donor Retained Interests (Trusts)

    • DAF

    • Special Case – Easements

  • Restricted Giving, Retained Interests


Tax and Procedural Considerations

  • IRC Section 170 - Charity in its Tax Context

  • Title Transfer and Completed Gift

  • Deductibility – The Prime Directive and the Primal Paradox (Donative Intent vs. Personal Benefit)

  • Deductibility - Limitations

    • AGI and Net Income (Current and Carryover)

    • Donor Restrictions and Earmarking

    • Partial Interests

    • Quid Pro Quo, Bargain Sales, and Personal Benefits

  • Substantiation and Documentation

    • General and Specific Disclosure

    • Minimum Sufficient Documentation

    • Special Cases

  • Valuation

    • Fair Market Value Standard and Approaches

    • Qualified Appraiser – Qualified Appraisal


Examination and Appeals Exposure-Procedure


IRS's Examination and Review Protocol

Historical and Institutional Context

History of Philanthropy, 2500BCE to 2021CE

  • Charity’s Religious Origins

  • Maimonides: Disinterested Generosity

  • Philanthropy – A Broader Modern Perspective - charitable, social, educational, scientific, public interest, sport, and religious causes


Charity and Charitable Intent – Philosophical and Economic Themes

  • The economics of Philanthropy

  • Incentives – the U.S. Tax Code

  • Who Gives? To Whom? How Much?

  • To Scam, or Not to Scam?


Sustainable Philanthropy


The Core of Giving in the US

  • Charitable Giving, US Historical Perspectives

  • Internal Revenue Code Sections 501c and 170

  • Estate and Gift Provisions

  • State Income, Estate, Gift, and Inheritance Factors

  • Enforcement - Examination, Appeals, Collections, and Penalties

Advisory Roles and Relationships

Organizational Perspectives

Sustainable Philanthropy

Formation and Maintenance

Operations and Management I

  • Accounting

  • Personnel and Compensation

  • Compliance and Reporting

  • Effectiveness

  • Governance

Operations and Management II

Examination and Appeals Exposure-Procedure

IRS Examination and Review Protocol

New, or Featured Publications

Our Sustainable Philanthropy letter addresses current topics that affect Exempt (Not-For-Profit) Organizations, Exempt Benefit Plans (Retirement and Health Care Planning) and those who want to make a lasting contribution to charitable causes (Philanthropists and Donors).

This edition includes the first results our Electric and Autonomous Vehicle Initiatives - Exploring the effect of portfolio weigh on yield and volatility, and provides a complete mathematical definition for each of the sixteen portfolios we examine. For this update (December 2021) we also feel confident when we present annualized gain or loss for the portfolio's securities


Organizations that maintain reserve or endowment funds need some essential documents. Here are samples and narrative about several of them: Investment Policies, Spending Policies, and Investment Committee Charters.

Like all templates, you need to run these by your legal counsel, tax representative, and investment advisor before you implement any of the provisions.  Cambyses Advisors will be glad to help implement your plan.

Endowment, Restricted, and Reserve Funds - Model Policies

Visit our Archive-Library

As part of our commitment to client, financial advisor, and tax-practitioner awareness and education Cambyses and our affiliate (Steven Roy Management) write extensively on topics related to our practice service-matrix (and occasionally on topics that are far-afield from it). To avoid cluttering our service pages with things very few people ever read (OK, we acknowledge - a lot of this stuff is just plain boring to other people), we collect the most current of those writings in our Archive & Library.

The Archive-Library materials range from "readily understandable by anyone who can read" to "you'll probably need professional credentials and experience to assimilate this one." You can usually determine which you are looking at by reviewing the footnotes and end-notes. The more referenced articles are designed for our colleagues - in the spirit of cooperation, and in the hope that we can contribute something to our profession. 

Note to our fellows and colleagues: Feel free to use any of our library materials in your own practice - just give us credit (and don't re-publish them without our permission and acknowledgement - that could get nasty). We welcome your feedback, constructive comments, and questions... we sometimes miss the obvious and your feedback helps remedy that. We view our colleagues as collaborators - not competition. There is plenty of work out there for all of us.

Apropos that last paragraph: Let us know what you do well - especially if it is a service we don't offer. We generate a "steady trickle" of referrals for other services and would be happy to add you to our referral list (after we've vetted you and  gotten to know you a bit). Contact us by email or phone to start the relationship.