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A charitable contribution that consists of less than the donor's entire interest in the property — called a gift of partial interest — generally does not qualify for a deduction, unless it is a gift of an undivided portion of the donor's entire interest. The IRS allows several exceptions to this rule prohibiting deductions for gifts of partial interest. These recognized exceptions to the general rule, each of which is reviewed in the following screens, include:

  • Charitable Remainder Trusts
    • Annuity Trusts

    • Unitrusts
  • Charitable Lead Trusts
  • Pooled Income Funds

Click here for a chart that summarizes the key advantages and disadvantages of each type of deductible gift of partial interest.

Charitable Split-Dollar Not Recommended

In the recent past, some insurance companies promoted a concept known as "charitable split-dollar life insurance." The IRS has since stated that a split dollar plan would be a gift of partial interest, and no deduction will be permitted. Accordingly, advisers are advised against recommending this approach or even raising the idea for discussion. Ohio National does not endorse or support the concept of charitable split-dollar life insurance.

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