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Young Pooled Income Fund

Your youngest clients
have the most to gain.

A 35-year-old founder with a concentrated position has 50 years of compounding ahead of them. A Young Pooled Income Fund captures all of it — eliminating capital gains, generating lifetime income, and reinvesting every tax advantage from day one.

Capital gains avoided
100%
No immediate recognition on contribution — the full position goes to work
Deduction advantage
Larger than a seasoned PIF
The "young" designation triggers the IRS deemed rate — not the fund's actual yield — producing a superior deduction
Lifetime income
For the donor's life
Pro-rata share of fund earnings, paid for the donor's lifetime — managed by the advisor, replacing the income that disappeared at exit
👨‍👧‍👦 Kids can be added too

The opportunity

The earlier the contribution,
the longer the compounding.

A founder who exits at 35 with $8 million in appreciated stock faces a decision most planning structures aren't built for. They have decades of income ahead to replace, a concentrated position they need to diversify, and a philanthropic identity they want to build — all at once.

A Young Pooled Income Fund is purpose-built for this moment. The full position enters the fund without triggering capital gains. The fund diversifies and invests — with 100 cents on the dollar working from day one. The donor receives lifetime income from the advisor-managed pool. And because the fund is new, the IRS deemed rate produces a charitable deduction that is systematically larger than an established fund would generate.

"The Young Pooled Income Fund is the structure that exists for exactly this client — and most advisors have never presented it."

Three advantages, one structure, administered entirely by GiftingNetwork. The only variable is time — and for a 35-year-old, there's plenty of it.

Scenario: $8M position, 5% basis, age 35
Fair market value$8,000,000
Cost basis$400,000
Embedded gain$7,600,000
Taxable sale — CG tax (23.8%) −$1,809,000
Net investable after sale$6,191,000
Young PIF — capital deployed$8,000,000
Young PIF contributes the full position with no immediate gain recognition. That $1.8M stays invested and compounds for the donor's lifetime — 50+ years for a 35-year-old.
How it works

Four advantages.
One structure.

A Young Pooled Income Fund is not a DAF, a CRT, or a foundation. It is its own vehicle — engineered for donors with appreciated, concentrated positions who need income, want to give, and can extend that income to the next generation.

01
📈

Capital gains bypass

Appreciated assets contribute to the fund without triggering immediate capital gain recognition. 100 cents on every dollar goes to work — not 76.

02
💰

Superior charitable deduction

Because the fund has no earnings history, the IRS mandates use of the "deemed rate" — typically the federal midterm AFR × 120%. In moderate rate environments, this produces a larger deduction than a seasoned fund's actual yield would generate.

03
📊

Lifetime income — advisor managed

The donor receives a pro-rata share of the fund's actual earnings for their lifetime. Critically, the advisor retains management of the pooled assets — building a long-term investment relationship that spans the full duration of the PIF, often decades.

04
🏛️

Multigenerational legacy

Adult children can be named as co-income beneficiaries, extending the income stream across generations. The charitable deduction is calculated using the youngest beneficiary's life expectancy — making this vehicle compelling well beyond the early-founder profile.

Why "young" matters

Time is the variable
nobody else prices in.

A Pooled Income Fund is "young" — by IRS definition — until it has three full years of earnings history. During this period, the fund uses a mandated deemed rate (120% of the federal midterm AFR) rather than its actual yield to calculate the charitable deduction.

In practice, this deemed rate is typically lower than a well-managed fund's actual yield. A lower rate means the charity's remainder is discounted less heavily — its present value is larger — and the donor's deduction is correspondingly larger.

But the more significant advantage is time itself. A 35-year-old who contributes $8M to a Young PIF avoids capital gains on the full position. That saved tax compounds for 50 years. A 65-year-old who takes the same trade gets perhaps 20 years of compounding. The deduction advantage is measurable. The compounding advantage is transformational.

Key point: Every dollar of capital gains tax avoided stays in the fund and earns returns for the donor's lifetime. For a 35-year-old, that's potentially 50+ years of compounding on the tax savings alone.

Young PIF advantage — age 35, $5M position (5% basis)
Capital gains avoided (23.8%)$1,130,500
Compounded 30 yrs @ 8%$11.37M
Deduction value (37% bracket)~$420K
Compounded 30 yrs~$4.2M
Income advantage (100¢ vs. 76¢)$1,190,000
Total Young PIF advantage~$15.6M
vs. taxable sale + invest over 30 yearsillustrative
Who it's for

Built for the advisors who
are already in the room.

The Young PIF conversation happens at a liquidity event — and the advisors who succeed with this vehicle are the ones present at that moment.

VC-Affiliated Wealth

VC-affiliated wealth management arms

Firms like a16z Perennial and GC Wealth are building family-office capability inside VC wrappers. Their clients are founders post-IPO or M&A — exactly the profile the Young PIF is designed for.

  • Clients have near-zero basis positions from founder equity
  • Charitable intent is often present but unstructured
  • Income need is real — the salary just ended
  • CRT is too complex; DAF doesn't pay income
Relevant firms
a16z PerennialGC WealthThrive CapitalLightspeed
Independent RIAs

RIAs serving tech executives & entrepreneurs

Firms like Cerity Partners, Brighton Jones, Pathstone, and Lido Advisors serve clients whose wealth came from RSUs, options, and business exits. Many have held appreciated positions for years and face the same tax wall.

  • Long-tenured tech employees with large RSU accumulations
  • Business owners who sold and held stock in the acquirer
  • Inherited concentrated positions with near-zero basis
  • Donors in their 50s and 60s who want to add children as income beneficiaries
Relevant firms
Cerity PartnersPathstoneBrighton JonesLido AdvisorsJordan Park
Estate & Tax Practitioners

Estate attorneys & tax advisors at liquidity events

M&A attorneys, CPAs, and estate planners present at the moment of transaction are often the first to surface the concentration problem — and the last to have a charitable income solution ready.

  • Pre-sale contribution structures for closely-held business owners
  • Post-sale planning for executives with lock-up expirations
  • Estate planning for inheritors of concentrated positions
  • Integration with existing trust and estate structures
Trigger events
IPO lock-up expiryM&A closeEstate settlementTender offer
The numbers

See the advantage
for your client's situation.

Adjust the inputs to match your client's profile. All three return tranches are shown — with deduction savings and CG tax avoided reinvested and compounded from year zero.

Young PIF — Total return vs. taxable sale & invest Illustrative only — not tax advice
CG tax avoided (compounded)
Deduction savings (compounded)
Income advantage
100¢ vs. after-tax base
Total Young PIF advantage vs. taxable sale
Young PIF (all tranches)
Taxable sale + invest

Assumes 8% total portfolio return. CG rate 23.8% (federal). Dividend yield 4.5%, qualified dividend tax treatment. Deduction savings and CG tax avoided reinvested at year 0 and compounded at portfolio return. Life expectancy interpolated from IRS Publication 1457 Table V. This is illustrative and does not constitute tax, legal, or investment advice.

⚠ Deduction limit: Contributions of appreciated assets to a PIF are deductible up to 30% of adjusted gross income in the year of contribution, with a 5-year carryforward for any excess. For large positions, the full deduction may be absorbed over multiple years. A tax advisor should model the actual utilization schedule based on the donor's projected AGI.

How we work together

You bring the client.
We handle everything else.

01

You identify the opportunity

A client with a concentrated position, charitable intent, and an income need. You recognize the profile and initiate the conversation — or GiftingNetwork can provide educational materials to share directly.

02

We prepare the analysis

GiftingNetwork produces a client-specific illustration showing all three return tranches — capital gains avoided, deduction savings, and lifetime income advantage — modeled to their exact situation.

03

Your client's counsel reviews

We work alongside the client's tax attorney and CPA to document the contribution, structure the investment strategy, and ensure the deduction is properly supported. We coordinate — you don't have to.

04

The fund is established and administered

GiftingNetwork establishes and administers the pooled income fund through our institutional sponsor network. Income distributions are handled quarterly. You remain the advisor of record — and you retain management of the fund's investment pool.

05

Your client gives with purpose

When the last income beneficiary passes, the fund remainder flows into a donor-advised fund held at GiftingNetwork's institutional sponsor. From there, grants can be directed to any qualifying public charity the donor's family designates — a permanent charitable endowment for the family's philanthropic legacy.

What GiftingNetwork provides
📊
Client-specific modeling

Detailed illustrations for any donor profile — age 25 to 80, any position size, any basis percentage. Branded with your firm if desired.

🏛️
Institutional fund administration

Full back-office administration through our network of community foundation and institutional sponsors. No operational burden on your firm.

💼
Advisor-managed investment pool

The advisor retains discretion over the fund's investment strategy — building a long-term managed asset relationship that spans the full duration of the PIF, often decades.

📋
Tax documentation

All deduction substantiation, K-1 preparation, and income reporting handled by our team. Coordinated directly with the client's CPA.

🤝
Referral relationship maintained

You stay the advisor. GiftingNetwork is the administrator. The client relationship — and the asset — stays with you.

About GiftingNetwork

The platform behind
institutional philanthropy.

GiftingNetwork is a donor-advised fund platform serving institutional sponsors — community foundations, Jewish federations, healthcare system foundations, and religious organizations — alongside their financial advisor networks.

Our platform operates as a three-sided marketplace connecting nonprofit DAF sponsors, financial advisors, and donors. Key partnerships with Orion Advisor Solutions and Envestnet provide access to approximately 200,000 financial advisors across the country.

GiftingPension represents our dedicated channel for the Young Pooled Income Fund — bringing a vehicle that has historically lived inside the planned giving community to the financial advisors and wealth managers who are present at the liquidity events where it matters most.

Structurally, GiftingNetwork's institutional sponsors serve as the first remainderman of every Young PIF we administer. When the last income beneficiary passes, the fund remainder flows into a donor-advised fund held at the sponsoring organization — from which the donor's family can recommend grants to any qualifying public charity over time. This sponsor DAF structure preserves maximum flexibility for the donor's philanthropic intent while satisfying the statutory requirements of IRC §642(c)(5).

200,000+
Financial advisors in our distribution network via Orion and Envestnet
3-sided
Marketplace: sponsors, advisors, and donors — all on one platform
50+ yrs
Maximum projection horizon for a 35-year-old donor — the full benefit window
Resource library

Everything your client's
counsel will ask for.

Technical primers, planning frameworks, and client-facing materials. Click any article to read in full.

Introducing GiftingPension: Pooled Income Funds for the Next Generation of Philanthropic Clients

The advisor's complete guide — why the Young PIF exists, who it serves, and why the CRT cannot serve the same client. Includes OBBBA implications, income character analysis, and the intergenerational planning opportunity.

  • What a Pooled Income Fund actually is
  • Why "young" is the planning lever — the deemed rate arithmetic
  • The CRT 10% remainder test — and why PIFs are exempt
  • Liquidity events, Roth conversion, intergenerational income
  • OBBBA 0.5% floor and why PIFs clear it
  • What the advisor retains: AUM, relationship, fees
  • Income character: qualified dividends and the 17-point spread
Read →

How the Young PIF Works: A Complete Technical Primer

The statutory foundation, the deemed rate advantage, and the three return tranches — explained for advisors and their clients' counsel.

Read →

Young PIF vs. CRT: Which Vehicle Wins?

A head-to-head comparison for advisors weighing both options for a client with a concentrated position.

Read →

Choosing the Young PIF Investment Strategy

High qualified dividend vs. dividend capture: how investment strategy shapes income character and net yield for donors.

Read →

Young Donors with Children: Multigenerational Planning

How naming adult children as co-beneficiaries extends the income stream and increases the deduction — for donors of any age.

Read →

IRC §642(c)(5) and the Deemed Rate: The Statutory Foundation

The regulatory basis for the Young PIF's deduction advantage — for tax attorneys and CPAs who need the cite.

Read →
Frequently asked questions

Questions advisors
ask before the first call.

What is a "Young" Pooled Income Fund?
A Pooled Income Fund is considered "young" — under IRS regulations — until it has three full years of investment earnings history. During this period, the fund uses a mandated deemed rate (120% of the federal midterm AFR) rather than its actual yield to calculate the charitable deduction for new contributions. This typically produces a larger deduction than an established fund's actual yield would generate.
How long does "young" last?
A fund is considered "young" until it has three full years of earnings history. After that, the deduction for new contributions is sized using the fund's actual 3-year average yield. GiftingNetwork manages this transition transparently.
Can the donor choose the charity?
Yes — with an important structural note. The first remainderman must be the fund's institutional sponsor. From there, the donor can recommend that grants flow to any qualifying public charity under IRC §170(b)(1)(A). Multiple charities can be designated, and the DAF wrapper at the sponsor gives the family ongoing flexibility to direct charitable distributions over time.
How is the income taxed?
Income distributions retain their character from the fund — ordinary income, qualified dividends, or a blend depending on the fund's investment strategy. Under the high qualified dividend strategy, the majority of distributions are taxed at preferential rates.
What happens at the donor's death?
When the last income beneficiary passes, the fund remainder flows to GiftingNetwork's institutional sponsor — typically into a donor-advised fund held at that sponsor. From there, the family can recommend grants to any qualifying public charity of their choosing. There is no estate inclusion of the remainder interest and no probate.
Do I lose advisory fees on the contributed assets?
Not necessarily. In certain fund structures, the advisor may retain discretion over the fund's investment strategy, maintaining the fee relationship. GiftingNetwork works with advisors on a case-by-case basis to structure the arrangement appropriately. Contact us to discuss your firm's specific situation.
Can children be named as income beneficiaries alongside the donor?
Yes — and this is one of the most underutilized features of the vehicle. A donor can name adult children as co-income beneficiaries, extending the cash flow stream beyond the donor's lifetime. Critically, the charitable deduction is calculated using the youngest beneficiary's life expectancy — making the Young PIF compelling well beyond the early-founder profile.
How does a Young PIF differ from a CRUT or CRAT?
A Charitable Remainder Trust is a separate trust created for a single donor — requiring trust drafting, separate tax filings, and ongoing trustee administration. A Young PIF is a pooled fund that GiftingNetwork administers on behalf of multiple donors, dramatically reducing cost and complexity.

Your youngest clients
are waiting for this conversation.

Schedule a 20-minute call with the GiftingNetwork team. We'll walk through the mechanics, discuss your client profile, and model the numbers for a specific situation — including the full 50-year compounding picture for a younger donor.

We work with RIAs, VC-affiliated wealth managers, estate attorneys, and CPAs. No platform commitment required to explore.