 The act also made collateral attacks on supporting organizations by forbidding donor-advised funds and private foundations from making qualifying distributions to Type III supporting organizations, and should they do so the distributions would become taxable subject to their respective excise taxes.Further restrictions, including explication of the payout rate contours will result from the Congress mandated survey that the IRS promulgated.In the Pension Protection Act, Congress mandated a study on the supporting organizations to understand their role in the exempt organization world and determine what future action remained necessary.