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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is made to or for the use of a charitable organization35

       To a gift of ordinary income property prior to application of the appropriate percentage limitation(s)36

       The transfer of an installment obligation to a charitable organization,38

       The transfer of an obligation issued at a discount to a charitable organization,39 or

       The assignment of income to a charitable organization.40

      In these circumstances, if the contributed property is capital gain property, the charitable deduction that would otherwise be determined must be reduced by the amount of the unrealized appreciation in value. The charitable deduction under these rules is confined to the basis in the property.


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