Appendix B. Charitable Contribution — 2025 Inst 990-T (PDF)

Charitable contributions. Filers should use the following information regarding the charitable contribution deduction to complete Form 990-T, Part I, line 4.

Corporations. The total amount claimed normally can’t be more than 10% of UBTI figured without regard to the following.

Any deduction for contributions.
Any capital loss carryback to the tax year under section 1212(a) (1).

Corporations on the accrual basis can elect to deduct contributions paid by the 15th day of the 4th month after the end of the tax year if the contributions are authorized by the board of directors during the tax year. Attach a declaration statement to the return stating that the resolution authorizing the contributions was adopted by the board of directors during the tax year. The declaration statement must also include the date the resolution was adopted. See Regulations section 1.170A-11.

Charitable contributions over the 10% limitation can’t be deducted for the tax year, but may be carried over to the next 5 tax years.

In figuring the charitable contributions deduction, if the corporation has an NOL carryover to the tax year, the 10% limit is applied using the taxable income after taking into account any deduction for the NOL.

To figure the amount of any remaining NOL carryover to later years, taxable income must be modified. See section 172(b). To the extent charitable contributions are used to reduce taxable income for this purpose and increase an NOL carryover, a contributions carryover isn’t allowed. See section 170(d)(2) (B).

Trusts. In general.

For contributions to organizations described in

section 170(b)(1)(A), the amount claimed may not be more than 50% of the UBTI figured without this deduction; and

For contributions to other organizations, the amount claimed may not be more than the smaller of:

a. 30% of UBTI figured without

this deduction; or

b. The amount by which 50% of

the UBTI is more than the contributions allowed in (1) above.

An increased limitation may be available for cash contributions under section 170(b)(1)(G).

Caution: Contributions not allowable in whole or in part because of the limitations may not be deducted as a business expense but may be carried over to the next 5 tax years.

Substantiation requirements. Generally, no deduction is allowed for any contribution of $250 or more, unless the organization gets a written acknowledgment from the donee organization that shows the amount of cash contributed, describes any property contributed, and either gives a description and a good faith estimate of the value of any goods or services provided in return for the contribution or states that no goods or services were provided in return for the contribution. The acknowledgment must be obtained by the due date (including extensions) of the organization’s return, or, if earlier, the date the return is filed. However, see section 170(f)(8) and the related regulations for exceptions to this rule. Don’t attach the acknowledgment to the return, but keep it with the organization’s records.

Note: For contributions of cash, check, or other monetary gifts (regardless of the amount), the organization must maintain a bank record, or a receipt, letter, or other written communication from the donee organization indicating the name of the organization, the date of the contribution, and the amount of the contribution.

Contributions of property other than cash. If an organization contributes property other than cash

Instructions for Form 990-T (2025) 39

The organization’s deduction may be reduced if rehabilitation credits were claimed on the building. See section 170(f)(14).
A $500 filing fee may apply to certain deductions over $10,000. See section 170(f)(13).

Reduced deductions for contribu- tions for certain property. The organization must reduce its deduction for contributions of certain capital gain property and qualified appreciated stock. See sections 170(e)(1) and 170(e)(5).

Special rules for corporations. A larger deduction is allowed for certain contributions of:

Inventory and other property to certain organizations for use in the care of the ill, needy, or infants (including contributions of apparently wholesome food (see section 170(e)(3)(C))); and
Scientific equipment used for research to institutions of higher learning or to certain scientific research organizations (see section 170(e)(4)).

See section 170, the related regulations, and Pub. 526, Charitable Contributions.