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C H A P T E R T W E N T Y2 0International Givingby Corporations§ 20.1 Corporate Gifts to U.S.Charity for Overseas Use 567§ 20.2 Gifts of Money fromForeign Affiliate ofU.S. Parent to OverseasCharity 568§ 20.3 Gift of Goods or Servicesto Benefit Foreign Charity 569§ 20.4 Grants of Funds fromU.S. Corporation-RelatedFoundation to ForeignCharity 570(a) Taxable Expenditures 570(b) Charitable Purpose 571(c) ExpenditureResponsibility 571(d) Overseas GranteeCategories 573(e) Grants to CharitableOrganizations andEquivalents 575(f) IRS SimplifiedProcedure 576(g) Grants to OtherOrganizations 577A dynamic aspect of the global market environment is the extension of corporatephilanthropy practiced by American companies doing business abroad. The taxlaw of the United States imposes certain limitations on overseas charitable giving,depending on the character of the donor and the donee. These constraintsare by no means barriers to transborder corporate giving. A U.S. corporationthat is planning to conduct philanthropic activities in a foreign country has severalmethods available for transferring contributions abroad.§ 20.1 CORPORATE GIFTS TO U.S. CHARITYFOR OVERSEAS USEA U.S. corporation may deduct up to 10 percent of its pretax net profits 1 for giftsmade to U.S. charitable corporations, 2 as charitable contributions, 3 even thoughthe gift may ultimately be used overseas. Certain adjustments to pretax net profits1 IRC § 170(b)(2).2 That is, corporations that are charitable by reason of IRC § 170(c)(2).3 IRC § 170(a)(1). 567