Exempt Organizations Advisory - IRS Issues Guidance on Recordkeeping Requirements for Workplace Giving Campaigns

Catherine W. Wilkinson (cwilkinson@steptoe.com)
Suzanne Ross McDowell (smcdowell@steptoe.com)
Randal T. Evans (revans@steptoe.com)

The IRS has released guidance on how taxpayers may comply with the recordkeeping requirements of IRC § 170(f)(17) when making charitable contributions through a workplace giving campaign, such as the Combined Federal Campaign (CFC), United Way Campaign, and similar workplace giving programs.  IRC § 170(f)(17), as added by the Pension Protection Act of 2006, requires a taxpayer to maintain a bank record or a written communication from the donee organization showing the name of the donee organization, the date of the contribution, and the amount of the contribution.  In Notice 2008-16, the IRS provides guidance on how these substantiation requirements apply in the case of a lump-sum contribution made through the CFC or a similar program. The guidelines are effective until the IRS issues regulations under IRC § 170 incorporating the recordkeeping requirements of IRC § 170(f)(17).