StacksVerified U.S. regulatory reference

26 CFR §1.681(a)-1

Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov ↗
Under section 681, the unlimited charitable contributions deduction otherwise allowable to a trust under section 642(c) is, in general, subject to percentage limitations, corresponding to those applicable to contributions by an individual under section 170(b)(1) (A) and (B), under the following circumstances;
  1. (a)To the extent that the deduction is allocable to “unrelated business income”;
  2. (b)For taxable years beginning before January 1, 1970, if the trust has engaged in a prohibited transaction;
  3. (c)For taxable years beginning before January 1, 1970, if income is accumulated for a charitable purpose and the accumulation is (1) unreasonable, (2) substantially diverted to a noncharitable purpose, or (3) invested against the interests of the charitable beneficiaries.