I also know the law perfectly well. I do this for a living.
I am not trying to get on your case. lol.
The problem that has arisen is: How will UC be accountable to the government?
Is UC claiming the donated shares as a charitable contribution on his personal Income Tax Return? If so, what is the name of the 501(c)(3) organization?
If UC gave the shares as a gift to specified individuals, how are these shares being reported to the IRS? Is each individual going to receive a 1099-MISC or is UC going to file a Gift Tax Return for each person receiving the donated shares?