The Tax Law of Charitable Giving. Bruce R. Hopkins

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The Tax Law of Charitable Giving - Bruce R. Hopkins


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knows how many.”103

      Contributions to religious organizations in 2019 totaled $128.17 billion (29 percent of all giving that year). Gifts to educational organizations amounted to $64.11 billion (14 percent); to human service entities, $55.99 billion (12 percent); to foundations, $53.51 billion (12 percent); to health care institutions, $41.46 billion (9 percent); to public/society benefit organizations, $37.16 billion (8 percent); to international affairs entities, $28.99 billion (6 percent); to arts, culture, and humanities entities, $21.64 billion (5 percent); and to environment and animals groups, $14.16 billion (3 percent).

      Contributions of corporate stock represented the largest share of total noncash gifts, in terms of value claimed. For 2016, corporate stock donations totaled $32.7 billion, an increase of 13.2 percent from 2015, representing 44.4 percent of all these donations. The average stock contribution per return in 2016 was $199,939. Gifts of clothing ($11.5 billion) constituted the second-largest category; the average such gift per return was $1,765.

      All adjusted gross income groups with incomes above $100,000 reported increases in deducted noncash contributions. The largest increase was by taxpayers in the $5 million–under $10 million group, who contributed $5.5 billion in value in 2016, an increase over the prior year of 37.9 percent. Taxpayers in the $10 million-or-more income group contributed 38.1 percent of all noncash gifts, or $28.1 billion.

      Private foundations received the largest share of these contributions, in the amount of $18.4 billion (25.1 percent of the total). The average of these gifts is $213,661 (the highest average gift amount for all types of charities). The next-largest type of charitable recipient was “large organizations”; they received $16.6 billion in noncash gifts.

      Donors aged 65 and over contributed the most, giving $27.8 billion (37.7 percent of the total); this is an average of $16,030 per return. Contributions of stock, mutual funds, and other investments by these taxpayers (the largest type of gift for this group) were $17.9 billion, representing 48 percent of the total amount.

      Statistics, of course, cannot provide the entire nonprofit sector picture. As the Commission on Private Philanthropy and Public Needs observed (albeit nearly 50 years ago), the “arithmetic of the nonprofit sector finds much of its significance in less quantifiable and even less precise dimensions—in the human measurements of who is served, who is affected by nonprofit groups and activities.” The Commission added:

      In some sense, everybody is [served or affected by


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