1)  People may be interested in looking at the IRS proposed regs on
corporate sponsorship.  Contact me if you want a copy.  Or if you want to
look for it yourself, the citation is:  EE-74-92.  It was published in
the Jan. 19, 1993 Federal Register.

The issue for the IRS is whether the charity is merely acknowledging the
sponsor's contribution or whether it is providing advertising
opportunities, in which case the sponsorship payment is treated not as a
gift but as taxable income under Unrelated Business Income Tax.

The regs wound up being amazingly lenient, mainly because the football
"bowl" games -- which are organized as charities, since they raise money
for the universities -- had serious lobbying power.  In the end, the IRS
said that a bowl could rename itself after the sponsor; that a contract
could call for TV cameras focusing on the corporate logo during the game;
that the very cups in which beer is sold in the stands could bear the
logo as well(!) -- and none of this is advertising.

There was also a legislative lobbying campaign to have sponsorship
payments removed from Unrelated Business Income Tax liability under
certain (very generous) circumstances.

At AAM we pretty much stayed clear, because it seemed that museums
wouldn't *want* such lenient rules, which after all put a lot of leverage
into the hands of the sponsors.  People on Capitol Hill were amazed that
we were trying to keep tax rules tight rather than loose -- practically a
first in their experience!

2)  On the subject of "perpetuity," there was a very interesting talk at
the ALI-ABA meeting a few years ago, entitled "How Long Is Forever?"  The
subject was wills, specifically those of Dr. Barnes and Isabella Stewart
Gardner.  It was given by the director of a museum in Philadelphia; he's
also a lawyer -- I think his name is Stephen Urice.

Andy Finch
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AAM Government Affairs

Usual disclaimers.