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ESTATE AND GIFT TAX CONSIDERATIONSsports competition (but not athletic facilities or equipment); to encourageart; or for the prevention of cruelty to children or animals (no netearnings to private shareholders or individuals, and not a disqualifiedorganization for attempted legislative influence, and no participation inpolitical campaigns)• Fraternal societies for use exclusively for religious, charitable, scientific,literary, or educational purposes, including encouragement of art or theprevention of cruelty to children or animals• Veterans’ organizations organized in the United States or a possession (nonet earnings to private shareholder or individual)The IRS, from time to time, issues rulings as to whether a transfer of moneyor property qualifies for the federal gift tax charitable deduction. 49Nonresidents who are not citizens of the United States are allowed to deductall gift transfers to or for the use of:• The United States, any state (including the District of Columbia), andpolitical subdivisions thereof for exclusively public purposes• Domestic corporations organized and operated exclusively for religious,charitable, scientific, literary, or educational purposes, or to encourage art,or for the prevention of cruelty to children or animals (no net earnings toprivate shareholders or individuals, and not a disqualified organization forattempted legislative influence, and no participation in political campaigns)• Trusts, funds, community chests, or foundations organized and operatedexclusively for religious, charitable, scientific, literary, or educational purposes,or to encourage art, or for the prevention of cruelty to children oranimals (no substantial part of activities for propaganda or to influencelegislation, and no participation in political campaigns), when the giftsare used exclusively within the United States for such purposes• Fraternal societies for use exclusively for religious, charitable, scientific,literary, or educational purposes, including the encouragement of art orthe prevention of cruelty to children or animals• Veterans’ organizations organized in the United States or a possession (nonet earnings to private shareholder or individual)The charitable deduction is subject to disallowance in certain cases. Transfersto certain charitable organizations subject to the termination tax applicablewith respect to private foundations 50 or to charitable organizations that are nolonger tax-exempt 51 do not qualify for the charitable contribution deduction.Generally, a transfer of a remainder interest in property to a charity is not entitledto a charitable gift tax deduction when the transferor retains an interest, ortransfers his or her retained interest to a donee, for a use other than the charitableuses described above. 5249 See, e.g., Priv. Ltr. Rul. 200324023.50 IRC § 508(d).51 IRC § 4948(c)(4).52 IRC § 2522(c). 232