zlacker

>>staran+(OP)
If OpenAI remains a 501(c)(3) charity, then any employee of Microsoft on the board will have a fiduciary duty to advance the mission of the charity, rather than the business needs of Microsoft. There are obvious conflicts of interest here. I don't expect the IRS to be a fan of this arrangement.

>>garris+EJ
Even if the IRS isn't a fan, what are they going to do about it? It seems like the main recourse they could pursue is they could force the OpenAI directors/Microsoft to pay an excise tax on any "excess benefit transactions".

https://www.irs.gov/charities-non-profits/charitable-organiz...