The formulas
- Floor (years beginning after 2025) = 1% x taxable income; contributions count only above the floor
- Ceiling = 10% x taxable income
- Current-year gifts are deducted first, then carryforwards, up to the ceiling
- Excess carries forward 5 years; floor amounts carry only from a year when the ceiling also binds
How it works
Section 170(b)(2) caps the corporate charitable deduction at 10 percent of taxable income computed with the adjustments in section 170(b)(2)(D). For taxable years beginning after December 31, 2025, only contributions above 1 percent of taxable income are deductible.
Contributions disallowed by the ceiling carry to the next year as a contribution of that year, current gifts first, and can be carried for five years under section 170(d)(2). Under section 170(d)(2)(C), gifts disallowed by the 1 percent floor carry forward only from a year in which the 10 percent ceiling also leaves a carryforward. In a year where the ceiling does not bind, the floor amount is lost. The floor applies to current-year gifts first and then to carryforwards.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Does the floor apply to carryforwards?
Carryforwards are treated as contributions of the later year, taken into account after the current-year gifts. This tool applies the floor to current-year gifts first and to carryforwards only if current gifts are smaller than the floor.
Does the amount below the floor carry forward?
Only when the 10 percent ceiling also leaves a carryforward from that year, under section 170(d)(2)(C). Otherwise it is lost.
What is the carryforward period?
Five years after the year the gift was first taken into account, used first in first out.
What taxable income do I use?
Taxable income computed as section 170(b)(2)(D) directs, which leaves out the charitable deduction itself and certain other items.
Sources
Runs in your browser. The figures you type are not sent to CORAA or stored. Check the result against your firm's methodology before relying on it.