Читать книгу The Tax Law of Charitable Giving - Bruce Hopkins R., Bruce R. Hopkins, David Middlebrook - Страница 69

This deduction reduction rule does not apply to reduce the amount of the charitable contribution when, by reason of the transfer of the contributed property, ordinary income or capital gain is recognized by the donor in the same tax year in which the contribution is made.³⁷ Thus, if recognition of the income or gain occurs in the same tax year in which the contribution is made, this rule is inapplicable when income or gain is recognized upon:

 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

Also, this deduction rule does not apply to a charitable contribution by a nonresident alien individual or a foreign corporation of property, the sale or other disposition of which within the United States would have resulted in gain that is not effectively connected with the conduct of a trade or business in the United States.⁴¹