Yes. Currently, DAF will not qualify as 100% AGI deduction until the IRS can establish clear guidelines for approval. Currently, the IRS "is aware of a number of organizations that appeared to have abused the basic concepts underlying donor-advised funds. These organizations, promoted as donor-advised funds, appear to be established for the purpose of generating questionable charitable deductions, and providing impermissible economic benefits to donors and their families (including tax-sheltered investment income for the donors) and management fees for promoters." Given the discretion given to the donor representative, they have advisory privileges with respect to the distribution of funds and the investment of assets in the account.
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