> To elaborate on what Michael said, we need to ensure the money remains used for
> the purposes for which SPI is tax-exempt, and also honor the more specific
> donor intent. For non-501(c)(3) organizations, additional steps have to be
> taken to ensure this well enough to satisfy the US tax authorities, hence the
> consultation with the attorney or CPA.
For that matter, we couldn't even transfer to "any 501(c)3". It would
have to specifically be a 501(c)3 supporting Free Software. Of course,
a foundation for a specific project would qualify.
Based on my own (non-professional) experience with NPOs, I'd say that
any transfer to a non-US non-profit is likely to be impossible, and
projects would be far better off just spending their money down to zero
than trying to transfer it.
--Josh Berkus