Steve Simmons wrote:

We're a state-funded institution as well, so 501c(3) for OpenAFS doesn't mean that much to us. But it can make a big, big difference for corporations or individuals donating funds or equipment. If I had enough bucks in my pocket to pay for, say, the native windows client implementation, I'd save 35% by giving to the foundation rather than paying SN/etc. As a corporation (say, Sun, IBM, HP) I'd get pretty much nothing by giving hardware to SN or an individual. By donating it to the 501, I can deduct the cost. Ditto for donating my proprietary OS software that I'd like to have AFS work correctly on.

Steve:

I think you are overstating the benefit.  A corporation that deducts the
cost of OpenAFS development in full as a business expense will receive a
larger tax write-off than by donating cash to the Foundation.  Hardware
that has been fully depreciated prior to donation also has no value from
the perspective of the corporation taxes.

The Foundation has a need to demonstrate that it is publicly supported.
As a result contributions of cash, copyrights which were purchased through development contracts with commercial development houses, donations of new hardware, donations of OS or DevTool licenses, etc., anything that has a market price can help demonstrate public support.

Copyright contributions that are not the result of a market purchase have no value according to the IRS because the value cannot be fairly determined.

Jeffrey Altman

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