DAFs have recently come into the limelight because of their frequently, if not inherent, use a tax shelter for high-net worth individuals. (Mr. Rayner of Plana would typically be classified as in that category, which is important to some of the points we will be making.) These donor advised funds have come under increasing scrutiny by the IRS, generally when a DAF is used to take an immediate tax deduction on an inflated asset valuation, then slowly granting it out to “friendly” nonprofits.
Now, investigating into the capital which Plana was able to procure to become operational, we see the American Endowment Foundation made a donation of about 3 million dollars in 2024. We also see that the PayPal Charitable Giving Fund made a donation of about 2 million dollars that same year.
This struck me as odd, because my knowledge of Plana suggested, and in fact was outright stated to me, that Mr. Rayner had directly funded Plana in addition to founding it.
So, the question then becomes, is Plana being used to support some sort of tax-shelter for an ultra-wealthy individual? (Whether legal or illegal is beyond the scope of this article, nor are the authors implying any conclusion.)
Now, while this question requires further investigation for concrete details, many of which will remain unanswerable because of the legal privacy protections provided to individuals, except for agencies such as the IRS, we believe it is important to ask the questions, even if they may be unanswerable to us, as individuals:
- What is the connection between Mr. Rayner, the American Endowment Foundation, the PayPal Charitable Giving Fund and Plana? Did Mr. Rayner make contributions of near equal value to these funds? (That’s a question we will probably not be able to answer, although again, in this author’s opinion it is suspicious that multiple people have claimed he was the only funder at this point, immediately before the time of writing.)
- Why are DAFs the overwhelming source of revenue for Plana?
- Should you trust a non-profit such as Plana which only has these types of donors?
- What agenda, if any, is this serving?
- How exactly did these DAFs find, approve, and fund Plana?
- If it can be shown that Mr. Rayner did in fact contribute to these DAFs and Plana employs friends of Mr. Rayner through these funds, does that then in and of itself imply tax fraud? This seems to be far more than the “incidental benefit” which is allowed for under DAF contributions. Furthermore, if that is indeed the case would it be egregious if those friends, and spouses of those friends, were also sponsored for H1B visas through employment at Plana?
So, What Does this Mean? What are We Suggesting Here?
Well, we’re not suggesting any conclusions. We are suggesting that the initial research points to some potentially sketchy answers. Does legal mean ethical? Again, we’re not sure. The only conclusion is that a superficial investigation into Plana and their funding does bring to light some interesting questions which we think should be considered.