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PERCENTAGE LIMITATIONS(b) Carryover RulesAny charitable contributions made by a corporation in a tax year (a contributionyear) in excess of the amount deductible in the contribution year under the 10percent limitation are deductible in each of the five immediately succeeding taxyears, in order of time, but only to the extent of the lesser of the followingamounts:• The excess of the maximum amount deductible for the succeeding taxyear, under the 10 percent limitation, over the sum of the charitable contributionsmade in that year, plus the aggregate of the excess contributionsmade in tax years before the contribution year that are deductibleunder these rules in the succeeding tax year• In the first tax year succeeding the contribution year, the amount of theexcess charitable contributions• In the second, third, fourth, and fifth tax years succeeding the contributionyear, the portion of the excess charitable contributions not deductibleunder these rules for any tax year intervening between the contributionyear and the succeeding tax year 132These rules apply to excess charitable contributions by a corporation,whether or not the contributions are made to or for the use of 133 the recipientcharitable organization and whether or not the donee is a public charitable organization.These rules may be illustrated by the following example:EXAMPLE 7.28Corporation X, which reports its income on the calendar year basis, made a charitablecontribution of $20,000 in 2005. X’s taxable income (determined without regard to anydeduction for charitable contributions) for that year was $100,000. Accordingly, the charitablecontribution deduction for 2005 was $10,000 (10% of $100,000). The excess charitablecontribution deduction not deductible in 2005 ($10,000) was a carryover to 2006.X had taxable income (determined without regard to any deduction for charitablecontributions) of $150 in 2006 and made a charitable contribution of $10,000 in 2006. For2006, X properly deducted as a charitable contribution the amount of $15,000 (10% of$150,000). This amount consisted of the $10,000 contribution made in 2006 and $5,000 of theamount carried over from 2005. The remaining $5,000 carried over from 2005 and notallowable as a deduction for 2006 because of the 10 percent limitation was carried over to2007.X had taxable income (determined without regard to any deduction for charitablecontributions) of $200,000 in 2007 and made a charitable contribution of $18,000 that year.For 2007, X was able to deduct $20,000 (10% of $200,000). This amount consisted of the$18,000 contribution made in 2007 and of $2,000 of the amount ($5,000) carried over from2005 to 2007. The remaining $3,000 of the carryover from 2005 was available as a charitablecontribution carryover from 2005 to 2008, 2009, and 2010. aaReg. § 1.170A-11(c)(1).132IRC § 170(d)(2)(A).133See § 10.3. 220