From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from lists.gentoo.org (pigeon.gentoo.org [208.92.234.80]) (using TLSv1.2 with cipher ECDHE-RSA-AES256-GCM-SHA384 (256/256 bits)) (No client certificate requested) by finch.gentoo.org (Postfix) with ESMTPS id 0F43A138239 for ; Wed, 3 Jul 2019 12:27:59 +0000 (UTC) Received: from pigeon.gentoo.org (localhost [127.0.0.1]) by pigeon.gentoo.org (Postfix) with SMTP id 3ED4BE0884; Wed, 3 Jul 2019 12:27:57 +0000 (UTC) Received: from mail-pl1-f195.google.com (mail-pl1-f195.google.com [209.85.214.195]) (using TLSv1.2 with cipher ECDHE-RSA-AES128-GCM-SHA256 (128/128 bits)) (No client certificate requested) by pigeon.gentoo.org (Postfix) with ESMTPS id C4809E0869; Wed, 3 Jul 2019 12:27:56 +0000 (UTC) Received: by mail-pl1-f195.google.com with SMTP id ay6so1159265plb.9; Wed, 03 Jul 2019 05:27:56 -0700 (PDT) X-Google-DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=1e100.net; s=20161025; h=x-gm-message-state:mime-version:references:in-reply-to:from:date :message-id:subject:to:cc; bh=sERDAVKR1OzUW7b8xpNEP7FCBE9mk6dSMJpNwF0knbw=; b=ZrakccnUanGYxlAg2Za3Jeb7nlyEU5H6hiC1XgCaof4UllNkgaRcPlhFHFDFhsnPZs r1LUPsuEmG5y+zZe7GkgLoe69pCi0IlKLq6l9A3RKU9baBdUp+HXBOoMi/4821qX16Sg U8ODmmBs0gVWb3kqqrzYr4oCmX4jBvhwx9fsAaxV993a5zymqP1d14ci6UM7I10/dKtE rAu6R4k4vd0bCjYKIjXDw1U/P5z6oWmasvR+gO2uPuxxAvX7LDw3EfHBQdHzV1W7PLCJ teGJYKpQgnFC+BfxLPRA0gqdc8Xt/bGyVmtTiC0iMqbDxpym96IeHwyt2z+X6y7g/rGV 5i0w== X-Gm-Message-State: APjAAAVdcMMUYFRG5PyfoSo3k7Z/JJfERF42PS01ACTiEVLdXbW2UAvG Xvh5fy9uANZYnO49QlEq2a+PHt0FbWUTng7MkQs= X-Google-Smtp-Source: APXvYqzEChzcoSwSQRYor96896Khf7f/hLFmU5zX0xPxMi097oRuLAnYhJKhpYqUbX3IACL2gkXhcRe7jtTq4wpJAPo= X-Received: by 2002:a17:902:70c3:: with SMTP id l3mr42053723plt.248.1562156875369; Wed, 03 Jul 2019 05:27:55 -0700 (PDT) Precedence: bulk List-Post: List-Help: List-Unsubscribe: List-Subscribe: List-Id: Gentoo Project discussion list X-BeenThere: gentoo-project@lists.gentoo.org Reply-To: gentoo-project@lists.gentoo.org X-Auto-Response-Suppress: DR, RN, NRN, OOF, AutoReply MIME-Version: 1.0 References: <86784617.NvtdGxuBOO@pinacolada> <635fbead-6e06-8d65-b1ec-3b05b47676e6@gentoo.org> In-Reply-To: <635fbead-6e06-8d65-b1ec-3b05b47676e6@gentoo.org> From: Rich Freeman Date: Wed, 3 Jul 2019 08:27:43 -0400 Message-ID: Subject: Re: [gentoo-project] Questions for Gentoo Council nominees: Gentoo Foundation - Treasurer Response! To: Kristian Fiskerstrand Cc: gentoo-project , gentoo-nfp Content-Type: text/plain; charset="UTF-8" X-Archives-Salt: 653b6572-e342-439b-b3b5-d8586c8a9c84 X-Archives-Hash: c8358b5865cfef162b5ceea7ad924112 On Wed, Jul 3, 2019 at 7:27 AM Kristian Fiskerstrand wrote: > > On 7/3/19 12:47 PM, Rich Freeman wrote: > > You also need to consider the tax savings themselves if the umbrella > > is 501c3. That is also a percentage of the net (the CPA costs being > > deductible most likely). > > It depends on the type of income, iirc e.g GSoC wouldn't be tax exempt > in either case. Same for royalties from sale of merchandise Certainly some forms of income aren't tax-exempt, and we should definitely get a professional opinion on this. However, have you seen anything to suggest GSoC specifically is taxable? I have been skimming the IRS materials, and in their training on the subject they specifically bring up the example of a once-a-year food stand that generates income at a conference, and that it wouldn't be taxable because it isn't "regular" income, being only once a year and doesn't really compete with a normal business that would be open every day [1]. However, I don't profess to be an expert on IRS tax law. It is probably a good idea to consider that some income will be taxable. Of course, it is still only net profits that are taxable, so any GSoC money spent on GSoC itself wouldn't be net-taxable even if the overall income would be (at least, that is my understanding). And of course if we were using an umbrella org the org itself would have its compliance staff make these determinations and have rules around this stuff. We wouldn't need to develop our own expertise and chances are their staff could also make recommendations on how to structure activities to minimize tax burden. If they're charging based on net income then it would be in their interests to minimize our taxes anyway. > > > > > You also need to consider services that we would receive that we > > currently lack. After all, Gentoo hasn't spent a dime on CPAs for a > > long time, but that was hardly a true savings. > > Also needs to account for potentially higher future earnings, we haven't > actually been doing active fundraising. I have mixed feelings on this. Numbers-wise you're right - if some professional umbrella org gets a shared of anything donated to "Gentoo" they're going to be out there advocating for people to donate to "Gentoo." As a result "Gentoo" will probably end up with a lot more money. On the surface this seems like a good thing. On the other hand, I do get concerned about what effect this could have on the community and atmosphere of the project. This is part of why I advocate for trying to reduce our dependency on money and servers and so on. These things all potentially come with strings attached, and I'd prefer to be more dependent on the goodwill of our code contributors than the goodwill of our financial/sponsorship contributors. I feel like a lot of bigger FOSS projects eventually reach a point where the people in charge end up with the opposite concerns - where they prefer all the core stuff to be paid so that they don't have to worry as much about the rank and file deciding they don't like the people in charge. As much as we have disagreements around here, I think that those in charge are very much community-oriented in their roots. Some might disagree, but I'd caution that to the degree that some disagree, the professional managers that come with big budgets are going to be FAR less to your liking. 1 - https://www.stayexempt.irs.gov/home/existing-organizations/unrelated-business-income -- Rich