Timing of Qualifying Investment
The credit shall be allowed for the taxable year in which the qualifying investment is made by a taxpayer. A qualifying investment is made at the time delivery is “effected” of the qualifying investment by a taxpayer investor to a qualifying business, as that term is used in Treas. Reg. § 1.170A-1(b). Accordingly, for example, the unconditional delivery of a cash contribution or mailing of a check by a taxpayer investor, which subsequently clears in due course, to a qualifying business, shall constitute an effective qualifying investment by the taxpayer investor on the date of delivery or mailing.