I think perhaps we need to rethink both the "foundation with members who (directly or indirectly) have outside, overlapping interests" and the "foundation that disburses money to employees, contractors, and/or other entities having special 'social good' / charitable tax status" elements of how a number of Free Software projects try to organise their ecosystem and make themselves sustainable. I base this on my own experience of having been 'in' a US 501(c)(3) foundation, and stories like this. My view is: 1. Trying to get many different entities, some of whom will have diverging and possibly competing interests, to ostensibly all work together under 1 "foundation" umbrella is a recipe for politics. In times past, I thought this was a good model. Now, having seen how this works, I don't think it is good. I have seen those controlling a "foundation" also have outside commercial interests (e.g., consultancies, or businesses), and it is inevitable this will lead to tensions between members and often abuse - to greater or lesser degrees. This becomes even worse when the foundation has significant costs and must raise money - either via donations/sponsorship or else via its own commercial activities. In the case of donations/sponsorship, this may lead to unhealthy practices such as those in control of the foundation using 'gatekeeping' powers (e.g., of membership, or even of willingness to accept contributions) to apply pressure to obtain donations (this I have seen people do in the one I was involved in). Now I think it would be better for the foundation to just be free-standing. It should employ or contract the regular developers directly. It should raise money via commercial activities ideally (at a minimum, via 0-commitment, limited-term, support contracts) - nothing else is sustainable in the long-run. 2. Such foundations should not be tax-exempt. Having seen what I've seen of numerous foundations (inc. inside one for a while), I think it's fairly obvious they exist primarily to fund developers/testers/documentation people to do the primary development work; and then sometimes a layer of management/business/marketing/events people (depending on how large). The latter layer can accrete with time and success, as is often the case with many organisational entitities. I just don't think this deserves a special tax-free status, at least not on donations and giving tax breaks to donors. Perhaps tax-breaks on retained profits would be good - and in some jurisdictions that may be achievable via certain non-profit structures, without requiring some special 'social good' or charitable status. If a foundation /does/ have a special 'social good' / charitable status, extending privileges, I really do think the foundation must be squeaky clean and free-standing, and go to significant lengths to avoid the messes and conflicts that arise otherwise - as described for concern #1 above. ## I'm not an expert on this stuff. I do think some currently common ways of organising larger Free Software projects may not be right, and new projects thinking of setting up legal entities should look at doing things differently and better.