Wolf, Inc. is a C corporation which holds a piece of land with a basis of $330,000 and a fair market value of $490,000. Wolf, Inc. does not have a use for the land and during a meeting in December of 2017 they decided to investigate the tax consequences of donating the land. Upon review of their prior year tax return they noticed they had a charitable contribution carryover of $375,000 from 2012. Taxable income for 2016 and 2017 is projected to be $4,000,000 and $5,300,000, respectively. The CFO of Wolf, Inc. has contacted you for advice on whether they should make the contribution in 2017 or 2018 (they must choose one year or the other). What is your advice and why?
Assumptions:
a) The donation has been made to a qualified organization.
b) It is a long term capital asset.
Solution:
Amount deductable will be: 100 of the fair value of the land donated i.e. $490,000.
Subject to the following condition i.e contribution to charitable organization shall be limited to 50% of the gross income computed without regard to net operating loss carrybacks.
Therefore if contribution is made in 2017: Amount of deduction available will be $4,000,000* 50% = $2,000,000
and for 2018 it will be $ 5,300,000*50%=$ 2,650,000. The maximum deduction available is $490,000 so the donation can be made in any year. The deduction available will be the same.
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