{"abstract":"This document provides proposed amendments to the regulations under sections 162, 164, and 170 of the Internal Revenue Code (Code). First, the proposed amendments update the regulations under section 162 to reflect current law regarding the application of section 162 to a taxpayer that makes a payment or transfer to an entity described in section 170(c) for a business purpose. Second, the proposed amendments provide safe harbors under section 162 to provide certainty with respect to the treatment of payments made by business entities to an entity described in section 170(c). Third, the proposed amendments provide a safe harbor under section 164 for payments made to an entity described in section 170(c) by individuals who itemize deductions and receive or expect to receive a state or local tax credit in return. Fourth, the proposed amendments update the regulations under section 170 to reflect past guidance and case law regarding the application of the quid pro quo principle under section 170 to benefits received or expected to be received by a donor from a third party.","action":"Notice of proposed rulemaking and notification of public hearing.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2019/12/17/2019-26969.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26}],"citation":"84 FR 68833","comment_url":null,"comments_close_on":"2020-01-31","correction_of":null,"corrections":[],"dates":"Written or electronic comments must be received by January 31, 2020 Requests to speak and outlines of topics to be discussed at the public hearing scheduled for February 20, 2020, must be received by January 31, 2020.","disposition_notes":null,"docket_ids":["REG-107431-19"],"dockets":[{"supporting_documents":[],"agency_name":"IRS","documents":[{"comment_count":45,"comment_start_date":"2019-12-17","updated_at":"2023-02-28T13:53:23.491-05:00","comment_url":"https://www.regulations.gov/commenton/IRS-2019-0056-0001","allow_late_comments":null,"id":"IRS-2019-0056-0001","comment_end_date":"2020-02-01","regulations_dot_gov_open_for_comment":false}],"supporting_documents_count":0,"id":"IRS-2019-0056","title":"Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)"}],"document_number":"2019-26969","effective_on":null,"end_page":68842,"executive_order_notes":null,"executive_order_number":null,"explanation":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2019/12/17/2019-26969.xml","html_url":"https://www.federalregister.gov/documents/2019/12/17/2019-26969/treatment-of-payments-to-charitable-entities-in-return-for-consideration","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2019-26969?publication_date=2019-12-17","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2019-12-17/2019-26969/mods.xml","not_received_for_publication":null,"page_length":10,"page_views":{"count":2946,"last_updated":"2026-04-24 14:15:03 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2019-12-17/pdf/2019-26969.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2019-26969.pdf?1576271720","publication_date":"2019-12-17","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2019/12/17/2019-26969.txt","regulation_id_number_info":{"1545-BP40":{"issue":"202004","html_url":"https://www.federalregister.gov/regulations/1545-BP40/treatment-of-payments-to-charitable-entities-in-return-for-consideration","title":"Treatment of Payments to Charitable Entities in Return for Consideration","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202004&RIN=1545-BP40&operation=OPERATION_EXPORT_XML","priority_category":"Other Significant"}},"regulation_id_numbers":["1545-BP40"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BP40/treatment-of-payments-to-charitable-entities-in-return-for-consideration","title":"Treatment of Payments to Charitable Entities in Return for Consideration"},"comments_count":45,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2019-0056","supporting_documents_count":0,"docket_id":"IRS-2019-0056","document_id":"IRS-2019-0056-0001","regulation_id_number":"1545-BP40","title":"Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)","checked_regulationsdotgov_at":"2023-02-28T18:53:22Z"},"regulations_dot_gov_url":null,"significant":true,"signing_date":null,"start_page":68833,"subtype":null,"title":"Treatment of Payments to Charitable Entities in Return for Consideration","toc_doc":"Treatment of Payments to Charitable Entities in Return for Consideration","toc_subject":null,"topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":84}