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PERCENTAGE LIMITATIONSThere is a 30 percent limitation, which is applicable when the contribution (orcontributions) is to one or more public charitable organizations and the gift orgifts are of capital gain property. 25 This rule applies with respect to gifts that donot have to be reduced by the amount of the appreciation element inherent in theproperty. 26 When a special election is made, contributions of capital gain propertymay be subject to the 50 percent limitation rather than the 30 percent limitation. 27In general, contributions of money to private foundations (and/or certainother donees, such as veterans’ organizations and fraternal organizations), in atax year, are deductible in an amount not in excess of 30 percent of the individualdonor’s contribution base for that year. 28 If the contributions are less, however,the limitation is an amount equal to the excess of 50 percent of the donor’scontribution base for the year over the amount of charitable contributions allowableunder the 50 percent limitation. 29Contributions of capital gain property to private foundations and certainother donee organizations are usually subject to a 20 percent limitation. 30Contributions by a corporation are deductible for a tax year in an amountnot to exceed 10 percent of the corporation’s taxable income, computed with certainadjustments. 31(b) Carryover RulesDonors of gifts that exceed the applicable percentage limitation are entitled tocarry the excess amounts forward, for purposes of deduction over the succeedingfive years, in order of time. The carryover rules apply to:• Individuals, in relation to the 50 percent limitation 32• Individuals, in relation to the 30 percent limitation, concerning gifts ofcapital gain property 33• Individuals, in relation to the general 30 percent limitation 34• Individuals, in relation to the 20 percent limitation 35• Corporations 36The carryover rules apply with respect to contributions made during a taxyear in excess of the applicable percentage limitation, even when the donorelects to use the standard deduction 37 for that year instead of itemizing thedeductions allowable in computing taxable income for that year. 3825 Id. See § 7.6.26 See §§ 4.5-4.7.27 IRC § 170(b)(1)(C)(iii). See § 7.7.28 IRC § 170(b)(1)(B)(i). See § 7.7.29 IRC § 170(b)(1)(B)(ii).30 IRC § 170(b)(1)(D)(i). See § 7.11.31 IRC § 170(b)(2).32 IRC § 170(d)(1).33 IRC § 170(b)(1)(C)(ii).34 IRC § 170(b)(1)(B), last sentence.35 IRC § 170(b)(1)(D)(ii).36 IRC § 170(d)(2).37 See Chapter 2.38 Reg. § 1.170A-10(a)(2). 192