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RECEIPT, RECORDKEEPING, AND REPORTING REQUIREMENTSTax regulations pertain to contributions made by means of withholdingfrom individuals’ wages and payment by individuals’ employers to donee charitableorganizations. (The problems in this setting include the fact that the doneecharity often does not know the identities of the donors/employees, nor theamounts contributed by each.) These regulations state that gifts of this naturemay be substantiated by both:• A pay receipt or other document (such as Form W-2) furnished by thedonor’s employer, setting forth the amount withheld by the employer forthe purpose of payment to a donee charity• A pledge card or other document prepared by or at the direction of thedonee organization that includes a statement to the effect that the organizationdoes not provide goods or services in whole or partial considerationfor any contributions made to the organization by payrolldeduction 41For purposes of the $250 threshold in relation to contributions made by payrolldeduction, the amount withheld from each payment is treated as a separatecontribution. 42 Thus, the substantiation requirement does not apply to contributionsmade by means of payroll deduction unless the employer deducts $250or more from a single paycheck for the purposes of making a charitable gift.The preamble to these regulations contains a discussion of this question: Can aForm W-2 that reflects the total amount contributed by payroll deduction, butdoes not separately list each contribution of $250 or more, be used as evidenceof the amount withheld from the employee’s wages to be paid to the doneecharitable organization? The IRS noted that the statute provides that anacknowledgment must reflect the amount of cash and a description of propertyother than cash contributed to a charitable organization. When a person makesmultiple contributions to a charitable organization, the law does not require theacknowledgment to list each contribution separately. Consequently, anacknowledgment may substantiate multiple contributions with a statement ofthe total amount contributed by a person during the year, rather than an itemizedlist of separate contributions. Therefore, said the IRS, a Form W-2 reflectingan employee’s total annual contribution, without separately listing theamount of each contribution, can be used as evidence of the amount withheldfrom the employee’s wages. (The IRS determined that the regulations need notaddress this point.)A charitable organization, or a Principal Combined Fund Organization forpurposes of the Combined Federal Campaign and acting in that capacity, thatreceives a payment made as a contribution is treated as a donee organization forpurposes of the substantiation requirements, even if the organization (pursuantto the donor’s instructions or otherwise) distributes the amount received to oneor more charitable organizations. 4341 Reg. § 1.170A-13(f)(11)(i).42 Reg. § 1.170A-13(f)(11)(ii).43 Reg. § 1.170A-13(f)(12). 588