–Often, the taxpayers never takes
possession of the donated property, which instead is directly transferred
or delivered to the charity
–Key: tax credit based on the
high value of the receipt far exceeds
§The
taxpayer’s cost in purchasing the donated property and
§Capital
gains taxes on the disposition of the property
§Recently introduced amendments with respect to split-receipting include provisions deeming the FMV of donated property to be its cost if the property was acquired within three years (or 10 years in certain circumstances) of making the gift
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