[OpenAFS] Re: [OpenAFS-devel] An open letter from the OpenAFS Council of Elders

Steve Simmons scs@umich.edu
Tue, 13 May 2008 10:14:43 -0400


On May 13, 2008, at 9:31 AM, Jeffrey Altman wrote:

> 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.

Correct. On the other hand, having software developed by donating avoids
a number of, er, interesting corporate issues. You don't have to develop
the internal expertise needed before beginning the work, you don't  
encumber
an existing employee nor hire another, ya-da, ya-da. If you have a  
feature-
specific need, donation can be cheaper and easier than getting a  
contractor.

And I was kind of hoping companies would donate their relatively new  
stuff
to make sure AFS runs on it, not fully depreciated stuff. Something  
running
the newest iteration of SPARC, etc. There's definitely a deduction for  
the
company in such a case, tho nothing like the full retail value. I've not
looked in a few years, but full depreciation used to take three to  
four years,
depending on which schedule you use. At that point there's some  
question as
to if we'd even want it.

> 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.

True. I was thinking of 'donating my proprietary OS software' in the  
sense of
HP giving the Foundation new copies of HP/UX as it comes out,  
Microsoft donating
various software they'd like AFS to run on, etc. Licenses and  
installable stuff,
not source.