Treasury Regulations · 26 CFR
§ 25.2522(c)-2. Disallowance of charitable, etc., deductions in the case of gifts made after December 31, 1969.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 2522(c)
Cite as 26 CFR § 25.2522(c)-2
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- July 11, 1974 by T.D. 7318
- Issued under
- 26 U.S.C. § 2522(c)
- Length
- 454 words · about 2 min to read
- Cross-references
- cites 7 Code sections and 1 regulation; cited by 1
¶(a) Organizations subject to section 507(c) tax. Section 508(d)(1) provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section 2522 for a gift to or for the use of an organization upon which the tax provided by section 507(c) has been imposed shall not be allowed if the gift is made by the donor after notification is made under section 507(a) or if the donor is a substantial contributor (as defined in section 507(d)(2)) who makes such gift in his taxable year (as defined in section 441) which includes the first day on which action is taken by such organization that culminates in the imposition of the tax under section 507(c) and any subsequent taxable year. This paragraph does not apply if the entire amount of the unpaid portion of the tax imposed by section 507(c) is abated under section 507(g) by the Commissioner or his delegate.
¶(b) Taxable private foundations, section 4947 trusts, etc. Section 508(d)(2) provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section 2522 shall not be allowed if the gift is made to or for the use of—
¶(1) A private foundation or a trust described in section 4947(a)(2) in a taxable year of such organization for which such organization fails to meet the governing instrument requirements of section 508(e) (determined without regard to section 508(e)(2) (B) and (C)), or
¶(2) Any organization in a period for which it is not treated as an organization described in section 501(c)(3) by reason of its failure to give notification under section 508(a) of its status to the Commissioner.
For additional rules, see § 1.508-2(b)(1) of this chapter (Income Tax Regulations).
¶(c) Foreign organizations with substantial support from foreign sources. Section 4948(c)(4) provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section 2522 for a gift to or for the use of a foreign organization which has received substantially all of its support (other than gross investment income) from sources without the United States shall not be allowed if the gift is made (1) after the date on which the Commissioner has published notice that he has notified such organization that it has engaged in a prohibited transaction, or (2) in a taxable year of such organization for which it is not exempt from taxation under section 501(a) because it has engaged in a prohibited transaction after December 31, 1969.
[T.D. 7318, 39 FR 25458, July 11, 1974]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 507 Termination of private foundation status
- § 508 Special rules with respect to section 501(c)(3) organizations
- § 2522 Charitable and similar gifts
- § 441 Period for computation of taxable income
- § 4947 Application of taxes to certain nonexempt trusts
- § 501 Exemption from tax on corporations, certain trusts, etc.
- § 4948 Application of taxes and denial of exemption with respect to certain foreign organizations
Regulations it cites
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 7318 (39 FR 25458)
Where it sits in 26 CFR
- Subchapter B Estate and gift taxes
- Part 25 Gift tax; gifts made after december 31, 1954
- Deductions
Nearby sections
- § 25.2521-1 Specific exemption.
- § 25.2522(a)-1 Charitable and similar gifts; citizens or residents.
- § 25.2522(b)-1 Charitable and similar gifts; nonresidents not citizens.
- § 25.2522(c)-1 Disallowance of charitable, etc., deductions because of “prohibited transactions” in the case of gifts made before January 1, 1970.
- § 25.2522(c)-2 Disallowance of charitable, etc., deductions in the case of gifts made after December 31, 1969.
- § 25.2522(c)-3 Transfers not exclusively for charitable, etc., purposes in the case of gifts made after July 31, 1969.
- § 25.2522(c)-4 Disallowance of double deduction in the case of qualified terminable interest property.
- § 25.2522(d)-1 Additional cross references.
- § 25.2523(a)-1 Gift to spouse; in general.