Shared Return Account
Initiative

Section 01

Executive Summary

The American philanthropic infrastructure has a structural flaw: it routes wealth through nonprofit intermediaries that capture meaningful fractions of the dollar before it reaches the people it is meant to serve. This proposal does not reform that infrastructure. It bypasses it.

The Shared Return Account (SRA) is a financial instrument that allows high-net-worth individuals to pledge the yield on qualifying invested assets to low-income families through direct, unrestricted cash transfers. The investor retains full ownership of principal, the asset continues to appreciate, and the principal transfers to heirs as planned. What changes is where the annual return goes.

Section 02

The Instrument: Shared Return Account

An SRA is a brokerage or trust account with a contractual overlay that directs a defined portion of annual investment return to a Certified Family Fund (CFF). The account operates as follows:

1. The investor deposits qualifying assets into the SRA with a participating custodian.
2. Assets are invested according to the investor's existing preferences. The SRA imposes no investment mandate beyond a five-year holding commitment and a prohibition on illiquid assets.
3. A Participation Threshold is defined at account establishment. The investor retains all return below this threshold. All return above the threshold, up to a pledged cap, routes automatically to the designated CFF.
4. The CFF makes unrestricted direct cash transfers to enrolled low-income families. No conditionality. No reporting burden on recipients.
5. Principal is never touched. It remains fully owned by the investor and transfers to heirs according to the estate plan.

CFF Certification Standards

A Certified Family Fund must meet annual certification requirements: minimum 80% of all disbursements as direct unrestricted cash transfers; administrative overhead capped at 15%; annual financial audit required. Organizations failing certification are removed from the eligible list and existing SRA holders are notified.

Why Unrestricted Transfers

The evidence base for unconditional direct cash transfers is among the strongest in antipoverty research. GiveDirectly, the Stockton SEED program, and UpTogether all demonstrate that low-income families allocate unrestricted cash to food, housing, and education at rates that exceed comparable administered program spending on the same categories, while generating secondary economic activity in their communities. Conditionality adds administrative cost and reduces family agency without improving outcomes.

Section 03

State-Level Framework: Georgia

Georgia's tax code already contains the mechanism needed. The Qualified Education Expense Credit (O.C.G.A. § 48-7-29.16) provides a dollar-for-dollar state income tax credit for contributions to qualified scholarship organizations. The SRA Georgia Civic Investment Credit is structurally identical: a targeted amendment to Title 48, adding one new subsection.

Georgia Incentive Stack

The Math at Various Account Sizes

Assumes 7% annual return, 50% yield donated, 37% federal marginal rate, 40% Georgia credit applied to full donation amount. Individual tax situations vary; consult qualified counsel.

Section 04

Pilot Design

The pilot runs for 18 months in Georgia under existing charitable contribution law, with the explicit goal of generating outcome data for the 2027 Georgia legislative session.

Geography

Three corridors: Atlanta MSA (Fulton, DeKalb, Cobb, Gwinnett), Savannah MSA (Chatham), and Augusta MSA (Richmond). Geography is selected to create a demographically diverse participant pool and build political relationships across House and Senate districts needed for 2027.

Founding Families

Twelve founding families. Minimum SRA commitment: $500,000 in qualifying assets. Each designates a single CFF from the certified list. Founding families receive the Founding Civic Investor designation, named recognition in the annual impact report, first-access advisory position, and introductions to peer founding families across corridors.

Certified Family Funds

Three CFFs participate in the pilot, one per corridor. Candidate organizations: UpTogether Georgia affiliate (Atlanta); Coastal Georgia Community Action Agency (Savannah); Augusta Neighborhood Improvement Corporation (Augusta). Each is evaluated against certification criteria before pilot launch.

Pilot Timeline

Section 05

Initial Funding

Funding Sources

Tier 1 — Founding family participation fees: $5,000 one-time per founding family at SRA establishment. 12 families = $60,000. Covers ~30% of Year 1 costs.

Tier 2 — Georgia community foundation planning grant: Atlanta Community Foundation and Community Foundation for Greater Atlanta together manage over $2B in assets with explicit economic mobility interests. A $75,000-100,000 planning grant is well-precedented and well-aligned.

Tier 3 — Pro bono legal: Atlanta's large law firms (Alston & Bird, King & Spalding, Troutman Pepper) have established pro bono programs. The SRA legal structuring work is a strong candidate, estimated at $35,000-55,000 in billable hours.

Tier 4 — State planning grant: Georgia Department of Community Affairs planning grants for economic development initiatives. $25,000-50,000. Requires a government champion.

Section 06

Operational Structure and Overhead Management

Three constraints govern the operating structure: minimum viable staffing, maximum automation, and strict ongoing overhead caps enforced publicly.

The 15% Hard Cap

The initiative commits publicly to an ongoing overhead cap of 15% of total funds routed. This is not an aspiration. It is a structural commitment enforced through the CFF certification process and published annually in the impact report. Exceeding the cap triggers a mandatory restructuring review.

The Initiative Never Touches the Money

Yield flows directly from the investor's custodian to the CFF's account, with no pooling or intermediary holding by the initiative. This is the single most important overhead-management decision in the design. By never touching the money, the initiative cannot spend it on itself.

Staffing

Year 1: 0.5 FTE Program Coordinator ($40,000-60,000 prorated). Year 2: full-time Executive Director ($80,000-110,000). Maximum of two full-time equivalents in Years 1 through 5. Growth is achieved by certifying more CFFs and onboarding more investor families, not by building institutional infrastructure.

Governance

501(c)(3) structure. Five-member board, meeting quarterly: two founding investor family representatives (rotating), one CFF representative (rotating), one independent civic leader, one legal or financial professional. Board members receive no compensation. Annual impact reports are published publicly with a standardized overhead disclosure table.

Section 07

Georgia Draft Legislative Language

Draft language for amendment to Title 48, Chapter 7 of the Official Code of Georgia Annotated. Modeled on O.C.G.A. § 48-7-29.16 (Qualified Education Expense Credit). Intended for legislative counsel review.

Short Title

A BILL
To amend Chapter 7 of Title 48 of the Official Code of Georgia
Annotated, relating to income taxes, so as to provide for the
Georgia Civic Investment Credit for qualified yield donations
made through a Shared Return Account; to define terms; to
establish certification requirements for Certified Family Funds;
to provide for tax credits; to provide for related matters;
to repeal conflicting laws; and for other purposes.

SECTION 1.
Chapter 7 of Title 48 of the Official Code of Georgia Annotated
is amended by adding a new Code section to read as follows:

'48-7-29.XX GEORGIA CIVIC INVESTMENT CREDIT

Key Definitions

(b) DEFINITIONS. As used in this Code section:

  (1) 'Shared Return Account' or 'SRA' means a brokerage or
  trust account established by a taxpayer with a qualifying
  custodian, subject to a written participation agreement that
  directs a defined portion of annual investment yield to a
  Certified Family Fund, provided that:
      (A) The account holds only publicly traded securities,
      cash equivalents, or other liquid assets;
      (B) The taxpayer's principal investment is not subject
      to transfer or encumbrance for the benefit of any CFF;
      (C) The participation agreement specifies a Participation
      Threshold below which no yield obligation arises;
      (D) The participation agreement has a minimum term of
      five (5) years from the date of establishment.

  (2) 'Qualified SRA Yield Donation' means the amount of annual
  investment return exceeding the Participation Threshold
  that is transferred directly from the SRA custodian to a
  Certified Family Fund pursuant to the participation agreement.

  (3) 'Certified Family Fund' or 'CFF' means an organization
  that:
      (A) Is exempt from federal income tax under Section
      501(c)(3) of the Internal Revenue Code;
      (B) Has received certification from the Georgia
      Department of Revenue pursuant to subsection (d);
      (C) Disburses no less than eighty percent (80%) of all
      funds received through SRA routing as direct,
      unrestricted cash transfers to enrolled low-income
      households;
      (D) Maintains administrative overhead at or below
      fifteen percent (15%) of total funds received.

  (4) 'Low-income household' means a household with annual
  income at or below eighty percent (80%) of the Area Median
  Income for the relevant MSA or county, as determined by HUD.

Tax Credit Provisions

(c) CREDIT.

  (1) For taxable years beginning on or after January 1, 2027,
  a taxpayer that makes a Qualified SRA Yield Donation to a
  Certified Family Fund shall be allowed a credit against the
  taxes imposed by this chapter equal to forty percent (40%)
  of the amount of such donation.

  (2) The credit shall not exceed the taxpayer's Georgia income
  tax liability for the taxable year. Unused credit may be
  carried forward for up to three (3) succeeding taxable years.

  (3) The aggregate amount of credits allowed under this Code
  section shall not exceed $25,000,000 in any calendar year,
  allocated on a first-come, first-served basis.

  (4) Early termination of an SRA within the minimum five-year
  period shall require recapture of all credits claimed in
  prior taxable years, plus interest at the rate provided in
  Code Section 48-2-35.'

Section 08

Federal Framework

Federal legislation is a Year 3 objective. The Georgia pilot must first demonstrate that the transfer mechanism works at scale without overhead creep, and that the credit produces new philanthropic behavior rather than subsidizing existing giving. With that data, the federal ask is straightforward.

Three Core Federal Proposals

Proposal 1 — Gross Income Exclusion: Qualified SRA Yield Donations excluded from gross income entirely. Yield routes from custodian to CFF without ever entering the taxpayer's gross income. Structurally identical to the Qualified Charitable Distribution treatment under I.R.C. § 408(d)(8), without the age restriction or IRA requirement.

Proposal 2 — Capital Gains Deferral: Assets held inside a designated SRA receive deferral treatment equivalent to a traditional IRA. No recognition of capital gain on realization within the account until withdrawal. This makes the SRA financially superior to a standard brokerage account on pure investment grounds, independent of the charitable benefit.

Proposal 3 — Federal Match (10-15 cents per dollar): For each dollar routed to a Certified Family Fund, the federal government contributes a 10-15% match. Funded through HHS as a pilot under TANF block grant authority or a new economic mobility line. Positioned as a more efficient alternative to equivalent administered spending.

Draft Federal Legislative Title

SHARED RETURN ACCOUNT ACT OF [YEAR]

To amend the Internal Revenue Code of 1986 to establish Shared
Return Accounts, to provide for exclusion of qualified yield
donations from gross income, to provide for deferral of capital
gains within such accounts, and to authorize a federal matching
program for qualifying family fund transfers.

SEC. 2. SHARED RETURN ACCOUNTS.

  (a) IN GENERAL. Gross income does not include any qualified
  SRA yield donation made by a taxpayer who has established a
  Shared Return Account with a qualifying custodian.

  (b) KEY DEFINITIONS.
      (1) SHARED RETURN ACCOUNT: an account established by
      an individual taxpayer with a qualifying custodian under
      a written participation agreement providing for the
      automatic transfer of a specified portion of annual net
      investment income, in excess of a defined threshold, to
      one or more Federally Certified Family Funds, provided
      that the taxpayer retains unrestricted ownership of
      principal.

      (2) QUALIFIED SRA YIELD DONATION: the amount transferred
      from an SRA to a Federally Certified Family Fund during
      the taxable year, not to exceed the taxpayer's net
      investment income for such year.

  (c) CAPITAL GAINS DEFERRAL. No gain or loss is recognized on
  the sale or exchange of property within a Shared Return
  Account. Gain or loss recognized only upon distribution to
  the account holder.

  (d) ANNUAL EXCLUSION LIMIT. The aggregate amount excluded
  from gross income under this section shall not exceed
  $1,000,000 in any taxable year.

Section 09

Recommended Next Steps

Immediate (30 Days)

1. Identify a Georgia tax and nonprofit attorney to review this brief and assess Year 1 operation under existing charitable contribution law.
2. Contact Atlanta Community Foundation and Community Foundation for Greater Atlanta to introduce the concept and assess planning grant interest.
3. Identify two to three founding family candidates: Atlanta-based, HNW, civic relationship, receptive to novel structures.
4. Contact UpTogether's national office to determine whether a Georgia affiliate can serve as the Atlanta CFF.

30-90 Days

1. Retain pro bono legal partner for SRA participation agreement and trust overlay documentation.
2. Form the pilot's legal entity (501(c)(3) application or fiscal sponsorship).
3. Secure commitments from six founding families at minimum $500,000 SRA commitment each.
4. Complete CFF certification review for at least two organizations.

90-180 Days

1. Execute custodian agreements with at least one participating financial institution.
2. Establish first SRAs. Route first yield disbursements to CFFs.
3. Begin legislative relationship-building: identify House and Senate sponsors, brief DOR staff on the proposed credit structure.
4. Contract with an independent evaluator for the 18-month evaluation.