Sources and provenance
This document lists where the drafts in this proposal drew from. It is organized by what the source informed, not by source type. Each entry notes whether the citation was verified during drafting or carried forward from general knowledge that should be re-checked before relying on it for filings.
A standing caveat: this proposal is a working draft. None of the legal claims in it have been confirmed by counsel. The point of the document set is to bring something concrete to a lawyer, not to be the lawyer’s output. Sources marked [verify before filing] are particularly important to confirm with current legal counsel; they reflect training-era knowledge that may have drifted.
Core legal structure: California Nonprofit Mutual Benefit Corporation + 501(c)(6)
California Corporations Code §§ 7110–8910 (Nonprofit Mutual Benefit Corporation Law) The statutory framework the bylaws skeleton is drafted against. https://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=CORP&division=2. [verify before filing]: citation pulled from training-era knowledge; confirm section ranges and current provisions with counsel.
IRS Form 1024 (Application for Recognition of Exemption Under Section 501(a)) The vehicle for seeking 501(c)(6) recognition after California incorporation. https://www.irs.gov/forms-pubs/about-form-1024 [verify before filing]: fee structure ($600 user fee referenced in docs) and processing times change periodically.
IRS guidance: Grants to foreign organizations by private foundations Background on expenditure responsibility rules under IRC § 4945 that apply to private foundations granting to international recipients via the Federation. https://www.irs.gov/charities-non-profits/grants-to-foreign-organizations-by-private-foundations https://www.irs.gov/charities-non-profits/private-foundations/grants-by-private-foundations-expenditure-responsibility
California Center for Cooperative Development: Legal Sourcebook Background reading on California democratic-governance entity structures. The Federation isn’t a co-op, but the underlying member-governance principles overlap. https://cccd.coop/sites/default/files/resources/LegalSourcebookForCaliforniaCooperatives_0.pdf
Reference architectures (federations operating in patterns similar to the proposed structure)
Linux Foundation bylaws The closest legal analog. 501(c)(6) federation with international members and corporate sponsorship. The Federation explicitly avoids Linux Foundation’s tiered membership model (Platinum/Gold/Silver with board seats), which creates the governance dynamics the destiny-lock clauses are designed to prevent. https://www.linuxfoundation.org/bylaws
Wikimedia movement affiliates and chapter agreements The most thoroughly documented federation-of-equals pattern. Each country chapter holds one equal vote regardless of size, which is the model for the Federation’s one-group-one-vote rule. - Affiliates portal: https://meta.wikimedia.org/wiki/Wikimedia_movement_affiliates - Chapter agreements (templates and signed examples): https://meta.wikimedia.org/wiki/Chapters_agreement - Movement Charter: https://meta.wikimedia.org/wiki/Movement_Charter
Apache Software Foundation 501(c)(3) educational, member-elected board, project-autonomy model. Different tax classification but similar federation-of-projects governance. https://www.apache.org/foundation/
Cloud Native Computing Foundation (CNCF) 501(c)(6) under the Linux Foundation umbrella. Referenced as an example of multi-tier sponsor structure with governance separation. https://www.cncf.io/
OpenJS Foundation Another Linux Foundation–style member federation in the JavaScript ecosystem. https://openjsf.org/
Mozilla Foundation international structure A US (c)(3) operating with separate entities in Germany and elsewhere. Reference for how a US-incorporated org can have international affiliates. https://foundation.mozilla.org/
Alternative jurisdictions evaluated
Belgium AISBL (Association Internationale Sans But Lucratif) Evaluated as the textbook European alternative. The European Activism Incubator was the practical resource consulted; it specifically advises against AISBL when a simpler form would suffice, and notes AISBL is often pursued for US-funder optics rather than legal necessity. https://www.activismincubator.eu/ [verify before filing]: Belgian notary fee estimates (~€2,000) and Royal Decree timeline (6–12 months) are training-era figures; current costs and processes should be confirmed with Belgian counsel if AISBL re-enters consideration.
Canada Not-for-profit Corporations Act (CNCA) The statutory framework for Canadian federal NFP corporations, identified as the lightest sister-entity path of any jurisdiction evaluated. - Act text: https://laws-lois.justice.gc.ca/eng/acts/c-7.75/ - Corporations Canada incorporation guide: https://ised-isde.canada.ca/site/corporations-canada/en/not-profit-corporations
Canada Revenue Agency: Charities and giving Reference for Canadian tax treatment of inbound foreign nonprofit funds. https://www.canada.ca/en/revenue-agency/services/charities-giving.html
UK Community Interest Company (CIC) Evaluated as the UK sister-entity option. Built-in asset lock satisfies the Federation’s bylaws requirement. https://www.gov.uk/government/organisations/office-of-the-regulator-of-community-interest-companies
Japan: General Incorporated Association (一般社団法人 / ippan shadan hojin) The Japanese form analogous to a California Mutual Benefit Corp. Created in Japan’s 2006/2008 nonprofit reform. - http://www.koekihojin.com/en/ - https://japan-law-tax.com/blog/npo-japan/ [verify before filing]: fee figures (~$700 USD all-in) and the requirement for a Shiho shoshi (judicial scrivener) for Japanese notarization came from training-era knowledge and Japan-side legal practice references; should be confirmed with Japanese counsel before any sister-entity filing.
Operational infrastructure
Open Source Collective (fiscal sponsor bridge) 501(c)(6) that hosts open-source meetups, advocacy groups, and federations. 10% fee. The recommended Phase 1 bridge while the Federation pursues independent incorporation. - Main: https://opencollective.com/opensource - Acceptance criteria: https://docs.oscollective.org/interested-in-joining-osc/acceptance-criteria - Terms of fiscal sponsorship: https://docs.oscollective.org/getting-started/terms-of-fiscal-sponsorship
Fiscal Sponsorship Allies (alternative fiscal sponsor option) Model C fiscal sponsor with broader scope than OSC. https://www.fiscalsponsorshipallies.org/
Aspiration (alternative fiscal sponsor option) Nonprofit fiscal sponsor focused on community organizing and tech-for-good. https://aspirationtech.org/
Nonprofits Insurance Alliance of California (NIAC) The default liability and D&O provider for California nonprofits. Cited for US event coverage; international coverage is handled separately. https://insurancefornonprofits.org/ [verify before filing]: premium estimates ($1,500–$4,000/year) are training-era figures; get current quotes.
Wise Business (multi-currency banking) Primary recommended banking for an international federation. Multi-currency accounts with local routing details in major currencies. https://wise.com/business
Mercury (US-domestic banking) Optional US-domestic banking partner. https://mercury.com/
Relay (multi-account budgeting) Optional banking for federation-style fund tracking, US-domestic. https://relayfi.com/
Data protection by region
EU GDPR (official text) https://eur-lex.europa.eu/eli/reg/2016/679/oj
UK GDPR (Information Commissioner’s Office guide) https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/
PIPEDA (Canada): Personal Information Protection and Electronic Documents Act https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/
APPI (Japan): Act on the Protection of Personal Information https://www.ppc.go.jp/en/legal/
Iubenda (privacy policy generator referenced as a practical tool) https://www.iubenda.com/
Legal help recommended for the founding work
Sustainable Economies Law Center: Resilient Communities Legal Café Sliding-scale California nonprofit legal advice. Recommended as the first stop for California-specific bylaws review. - Calendar: https://www.theselc.org/cafe_calendar - Background: https://www.theselc.org/cafe - Free legal guide library: https://www.theselc.org/programs
Adler & Colvin San Francisco law firm specializing in nonprofit law including cross-border work. Recommended as the second-opinion firm for international-scope questions after SELC. https://www.adlercolvin.com/
Wagenmaker & Oberly Another nonprofit law firm with practical resources on international grantmaking, expenditure responsibility, and equivalency determinations. https://www.wagenmakerlaw.com/blog
Council on Foundations: International grantmaking resources Reference material for US-incorporated nonprofits making cross-border grants. https://www.cof.org/content/international-grantmaking
TechSoup Global / NGOsource Equivalency determination services for cases when US funders need a good-faith determination that an international grantee is equivalent to a US public charity. https://www.ngosource.org/
CAF America US-based intermediary for international charitable grantmaking. Sometimes the easiest path for a US funder to give to an international member group is through CAF America rather than through the Federation. https://cafamerica.org/
Code of Conduct templates referenced
The provisional Code of Conduct (Document 12) was adapted from these sources, with modifications for the Federation’s federation-of-equals structure and international scope.
Citizen Code of Conduct: closest fit for an in-person meetup federation. Licensed under CC BY 3.0. https://github.com/stumpsyn/policies/blob/master/citizen_code_of_conduct.md
Contributor Covenant: widely adopted open-source CoC. https://www.contributor-covenant.org/
Conference Code of Conduct (Geek Feminism wiki version): widely adapted for in-person events. https://geekfeminism.fandom.com/wiki/Conference_anti-harassment/Policy
Community and ecosystem context
atmosphere.community communities directory The directory of 23 local atproto groups across North America, South America, Europe, and online. The Federation proposal is structured to serve groups already visible in this directory. https://atmosphere.community/communities
atproto.camp Local user group hubs. Referenced as an alternative directory listing several of the same communities. https://atproto.camp/
atproto.wiki working groups The existing pattern of collective community work on the protocol layer. Referenced as evidence that the federation-pattern is already familiar in this community. https://atproto.wiki/en/working-groups
Political and regulatory context (US, 2025–2026)
Claims in the briefing about the current US political environment for nonprofits draw on general reporting and policy analysis from 2025–2026. Specific claims worth verifying with current sources before relying on:
- Executive orders directing federal agencies to review NGO funding
- Expanded “global gag rule” applying to non-military foreign assistance
- State-level “foreign agent” registration legislation in multiple US states
- US withdrawal from international organizations and treaties
- Travel restrictions affecting cross-border movement
- IRS authority over 501(c)(3) status
The Federation’s proposal is structured to sit outside the direct line of these pressures (501(c)(6) rather than (c)(3); no federal funding sought), but the political situation evolves and should be re-checked before incorporation.
[verify before filing]: these are general claims about the policy environment that should be confirmed against current reporting at the time of incorporation.
Conversational and contextual sources
These shaped the proposal but aren’t conventional citations:
The RSVP roster for the working session (ATProto LA, ATProto Boston, ATProto PDX, ATProto Seattle, ATBrasil, with NYC/Colorado/Norway expressing interest) came from outreach by the organizers bringing this proposal and is current as of the conversation drafting these documents.
The destiny-lock thresholds and funder concentration limit (40% maximum from any single funder for two consecutive years) are working-group judgment calls. Not drawn from any single source; calibrated against the destiny-lock provisions in Wikimedia, Mozilla, and Linux Foundation governance documents.
The Article XIII Affiliate provisions are inspired by the Wikimedia chapter agreement model and by the Linux Foundation’s project-affiliation structure, with structural modifications to ensure peer rather than hub-and-spoke relationships.
The asynchronous-default voting principle is informed by the practical reality of organizing across Tokyo-to-LA time zones (a 16–17 hour offset), where no synchronous meeting window exists with both regions awake during reasonable hours. This was treated as a load-bearing design constraint rather than a preference.
What is NOT a source for this proposal
For clarity in case any reader is wondering:
- No AT Community Fund or Raft Foundation documents were consulted in drafting. The proposal acknowledges these entities exist and treats them as potential future funders, but the federation is not modeled on either of them.
- No private legal advice has been obtained. Every legal claim in the document set is a working hypothesis pending SELC and Adler & Colvin review.
- No filings have been made. The documents are pre-incorporation working drafts.
How to use this list
If you’re sharing the federation proposal with another organizer, lawyer, or AI agent for review, this sources document accompanies the document set so reviewers can trace claims back to their grounding.
If you’re a lawyer reviewing this proposal: the most important entries for your review are the California Corporations Code, IRS Form 1024 guidance, the Linux Foundation bylaws (as a structural analog), and the international jurisdiction references for any sister-entity provisions.
If you’re a non-US founding member group reviewing this proposal: the jurisdiction-specific entries under “Alternative jurisdictions evaluated” and “Data protection by region” are the ones that affect your group most directly.