Irs Code Section 170

F disallowance of deduction in certain cases and special rules.

Irs code section 170. A private foundation cannot make a grant for a purpose not described in section 170 c 2 b of the internal revenue code. 2 when method may be adopted. Permitted purposes are religious charitable scientific literary or educational fostering national or international amateur sports competition but only if no part of the activities involve providing athletic facilities or equipment and preventing cruelty to children.

A common bargain sale is a transfer of real estate to a. Ii providing for the determination of an amount to be treated as net income of the donee which is properly allocable to qualified intellectual property in the case of a donee who uses such property to further a purpose or function constituting the basis of the donee s exemption under section 501 or in the case of a governmental unit any purpose described in section 170 c and does not possess a right to receive any payment from a third party with respect to such property. The buyer a qualified 501 c 3 charitable entity purchases and either operates the golf course or sells the property at a profit that they can use for their activities.

The term one or more organizations described in section 170 b 1 a other than clauses vii and viii as used in sections 507 and 509 of the internal revenue code code and the regulations means one or more organizations described in paragraphs b through f of this section except as modified by the regulations under part ii of subchapter f of chapter 1 or under chapter 42. Internal revenue code section 170 f 8 charitable etc contributions and gifts. 170 a 1 general rule there shall be allowed as a deduction any charitable contribution as defined in subsection c payment of which is made within the taxable year.

The expenditures so treated shall be allowed as a deduction. 2 to claim a charitable contribution deduction a taxpayer must establish that he or she made a gift to a qualified entity organized and operated exclusively for an exempt purpose no part of the net earnings of which inures to the benefit of any private shareholder or individual. A bargain sale to a charitable organization is the sale of a good or service to a charity for the amount less than the fair market value.

The strategy follows the irs code 170 bargain sale whereby the seller pays the top tax rate of 39 6 on earnings from other sources.