Bigger gifts, appreciated assets, and the new OBBBA math on what a deduction is worth
A Tax Alpha Companies playbook for CPAs
Charitable giving is the rare strategy that clients want to do and still routinely botch — not because the intent is missing, but because the execution and timing are wrong. A gift made carelessly on December 30 can be worth a fraction of the same gift structured in October. And beginning in 2026, the OBBBA has changed the arithmetic in ways that reward planning and penalize waiting.
This is fourth-quarter work because the deadline is absolute: a gift counts for the current year only if it is completed by December 31. For the client having an unusually high-income year — a business sale, a large bonus, a Roth conversion — the value of a deduction is highest right now, in the year the income lands. The job is to pair the gift with the income and to structure it for maximum efficiency.
Three techniques do most of the work. None is exotic; all are underused.
This is the single most efficient charitable move and the most frequently missed. A client who donates long-term appreciated securities (held more than a year) directly to a public charity gets two benefits at once:
Compare that to selling the stock, paying the gains tax, and donating the after-tax cash — the client gives less and deducts less. Donating the appreciated position in kind is strictly better whenever the asset has a meaningful embedded gain. The same logic extends to appreciated real estate and other long-term capital-gain property, subject to tighter deduction limits (below).
Since the standard deduction is large, many clients get no tax benefit from ordinary annual giving — their itemized deductions never clear the standard-deduction threshold. Bunching solves this: the client front-loads several years of intended giving into a single year, itemizes big that year, and takes the standard deduction in the off years.
A donor-advised fund (DAF) makes bunching practical. The client contributes a lump sum (ideally appreciated securities) to the DAF now, takes the full deduction this year, and then recommends grants to operating charities over the following years on their own schedule. The charities still receive steady support; the client captures the deduction in the high-value year.
For a client sitting on a large, highly appreciated, or illiquid asset — a concentrated stock position, a piece of real estate, a business interest — a charitable remainder trust (CRT) can do what an outright gift cannot. The client contributes the asset to the trust, which can then sell it without an immediate capital-gains tax, reinvest the full proceeds, and pay the client (or another beneficiary) an income stream for life or a term of years. The client takes a partial charitable deduction now for the present value of the remainder, and whatever is left at the end goes to charity.
A CRT spreads the gain, produces income, and delivers a current deduction — the right tool when an outright gift is too much and a straight sale is too costly.
Beginning in 2026, the One Big Beautiful Bill Act changes what a charitable deduction is worth, in two ways that every giving client should understand:
There is also a new above-the-line deduction for non-itemizers — up to $1,000 (single) / $2,000 (married filing jointly) — a modest benefit for the client who takes the standard deduction.
The planning point: for a top-bracket client contemplating a very large gift, it is worth modeling whether accelerating or bunching the gift, and whether giving appreciated assets versus cash, produces a materially better result under these rules. The changes reward deliberate timing.
A deduction lands in the current year only if the gift is complete by December 31. This is where good intentions die on the calendar:
And the deduction ceilings still apply: generally 60% of AGI for cash gifts to public charities, 30% of AGI for long-term appreciated property, with a five-year carryforward for any excess. A very large gift may deduct over several years even when it is completed in one.
A strong candidate:
Where it needs care:
Charitable planning is where the difference between a good intention and a well-structured, well-timed gift shows up directly on the return — and the OBBBA has raised the stakes on getting it right. If you have a client planning a meaningful gift this year, it's worth structuring before the calendar closes.
Ross Brannon · Tax Alpha Companies
C: 850-566-7999 · ross@taxalphacompanies.com
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Dollar thresholds and the OBBBA provisions described here reflect law as enacted and take effect beginning in 2026; verify current figures before relying on them. This material is provided for educational and informational purposes only and does not constitute legal, tax, accounting, or investment advice. The strategies discussed are general in nature and may not apply to specific individual circumstances. Any examples are hypothetical illustrations and are not a guarantee of any particular result. Tax laws are complex and subject to change; readers should consult qualified tax and legal professionals before acting on any strategy discussed.