The Internal Revenue Service has issued interim guidance on several thorny issues of interpretation of the charitable “reforms” of the Pension Protection Act (PPA) signed by President Bush in August. (See Ready Reference Page: “Congress Passes Charitable Reforms.”)

In Notice 2006-109, the Service has provided standards by which private foundations may determine whether they may make grants to supporting organizations, ruled that it won’t enforce certain excess benefit transactions for a year, excluded certain employer-sponsored disaster relief funds from the classification of donor advised fund so that they may make grants to individuals, and grandfathered certain multi-year scholarship grants.

The guidance was requested by the Council on Foundations and may be followed by further interpretations as the Service develops additional positions on the issues.