Page 411 - Small Business IRS Training Guides
P. 411
Audit Considerations
The only charitable contributions that are deductible by the S portion of an ESBT are those that pass-through an
S corporation as a separately-stated item shown on Sch. K-1.
The charitable deduction within the S portion of an ESBT is now subject to the same AGI limitations that are applicable to
individuals. The AGI of the S portion of an ESBT is computed in the same manner as an individual taxpayer, except that
administrative costs allocable to the S portion (to the extent they are costs incurred in the administration of the trust that
wouldn’t have been incurred if the property were not held by a trust) may be deducted in determining AGI.
Summary
The S portion of an ESBT that is not a grantor trust determines its charitable deduction using the rules applicable to
individuals and may carry forward charitable deductions that cannot be used due to AGI limitations.
73233-102 13542-4 Tax Cuts and Jobs Act