Corporate Partner Can Claim Charitable Contribution Deduction for Contributions Made by Partnership

Corporate Partner Can Claim Charitable Contribution Deduction for Contributions Made by Partnership

News story posted in Email Chief Counsel Advice on 8 July 2009| comments
audience: National Publication | last updated: 18 May 2011
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Summary

The Service has issued Email Chief Counsel Advice in which it concludes that a corporation that is a partner in a partnership can take a deduction for a charitable contribution made by the partnership as though the C corporation actually made the contribution from its distributive share.

ECC 200927034

Full Text:

UILC: 702.01-02, 170.02-01
Release Date: 7/2/2009

ID: CCA-513114-09

Office: * * *

From: * * *
Sent: Tuesday, May 12, 2009 2:33 PM
To: * * *
Cc:
Subject: ยง 170(e)(3) -- Contribution by Corporate Partner

Per our discussion earlier today, it is the view of * * * that Subchapter K provides that charitable contributions are to be taken into account by partners as if they themselves made the contributions. * * * found nothing in the legislative history of section 170(e)(3) that indicates it would not apply to C corporation partners of a partnership, and thus concurs with the views of * * * Therefore, a C corporation that is a partner in a partnership can take the enhanced deduction (if the charitable contribution is otherwise a qualified contribution as provided in section 170(e)(3)) for a charitable contribution made by the partnership as, under Subchapter K, C corporation is treated as though C corporation actually made its distributive share of the contribution.

Please feel free to contact * * *at * * *, or myself if you have any further questions.

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