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§ 7.8 GENERAL 30 PERCENT LIMITATIONbase for the tax year. 95 Separate rules apply when the property is long-term capitalgain property and is contributed to charitable organizations other than publiccharitable organizations. 96This limitation applies to donees such as private foundations, veterans’organizations, fraternal organizations, and certain cemetery companies. 97EXAMPLE 7.13This example may be compared with Example 7.1. A had, for 2005, a contribution base of$100,000. During 2005, she made charitable contributions of money, in the amount of$45,000, to a private foundation. A was allowed a charitable contribution deduction for 2005of $30,000 (30% of $100,000).In some instances, however, the actual annual limitation on deductible giftsof this nature is less than the 30 percent limitation. This occurs when gifts ofmoney and/or capital gain property to public charitable organizations are alsomade in the same contribution year. Thus, if the amount is less, the limitationwill be an amount equal to the excess of 50 percent of the donor’s contributionbase for the year over the amount of deductible charitable contributions thatare allowable under the 50 percent limitation. 98 This rule is discussed morefully below. 99As noted previously, these rules as applicable to money also apply to certaintypes of property. Thus, this general 30 percent limitation applies to gifts ofmoney, ordinary income property, and short-term capital gain property.(b) Carryover RulesIn general, the excess of:the amount of the charitable contribution or contributions of capital gainproperty made by an individual in a contribution year to one or more publiccharitable organizationsdivided by:30 percent of the individual’s contribution base for the contribution yearis treated as a charitable contribution paid by the individual to a public charitableorganization, subject to the 30 percent limitation, in each of the five tax yearsimmediately succeeding the contribution year, in order of time. 100 As noted previously,for federal income tax purposes, when the carryover rules are applied,an amount paid to a charitable organization in one year is treated as paid to thecharitable organization in a subsequent year.95IRC § 170(b)(1)(B)(i).96See § 7.12.97IRC §§ 170(c)(2)-(5).98IRC § 170(b)(1)(B).99See §§ 7.9, 7.10.100IRC § 170(b)(1)(B), last sentence. 207