Important notices
This document is proprietary and confidential to Global Capital for Good, a Delaware non-profit corporation, which sponsors the institution described here. The sponsor is incorporated; the entities described in this proposal are not. Neither the New York not-for-profit corporation nor the Luxembourg foundation has been formed, and no charitable registration, tax exemption or regulatory approval — including recognition under section 501(c)(3) — has been obtained by any entity in the architecture. No tax deductibility of any contribution is claimed or implied. All amounts, allocations, ratios and leverage examples are illustrative planning figures, not commitments, forecasts or promises to donors. Nothing in this document is legal, tax or investment advice, and nothing in it constitutes a solicitation of donations or an offer of securities or fund interests in any jurisdiction. The structure described is subject in its entirety to review by New York and Luxembourg counsel, including confirmation of the Luxembourg legal form (use of the word “foundation” is regulated by the Luxembourg Ministry of Justice), the US public-charity strategy, and the cross-border grantmaking framework.
Sources
- New York Department of State — Certificate of Incorporation for Domestic Not-for-Profit Corporationsdos.ny.gov/certificate-incorporation-domestic-not-profit-corporations-0
- Internal Revenue Service — Frequently asked questions about Form 1023irs.gov/charities-non-profits/frequently-asked-questions-about-form-1023
- Internal Revenue Service — Grants by private foundations: expenditure responsibilityirs.gov/charities-non-profits/private-foundations/grants-by-private-foundations-expenditure-responsibility
- Internal Revenue Service — Grants to organizations; program-related investmentsirs.gov/charities-non-profits/private-foundations/grants-to-organizations
- Internal Revenue Service — Grants to foreign organizations by private foundationsirs.gov/charities-non-profits/grants-to-foreign-organizations-by-private-foundations
- Ministère de la Justice (Luxembourg) — Fondationsmj.gouvernement.lu/fr/service-citoyens/fondations.html
- Ministère de la Justice (Luxembourg) — Associations sans but lucratifmj.gouvernement.lu/fr/service-citoyens/asbl.html
- Commission de Surveillance du Secteur Financier — Investment fund managerscssf.lu/en/2026/06/investment-fund-managers
- Fondation de Luxembourg — Create a Foundationfdlux.lu/en/create-a-foundation
- Infra One — Launching a RAIF in Luxembourg: timeline and costsinfra.one/insights/luxembourg-raif-launch-end-to-end