Page 167
139 STAT. 237 PUBLIC LAW 119–21—JULY 4, 2025 ‘‘(i) IN GENERAL.—For taxable years beginning after December 31, 2017, any contribution of cash to an organization described in subparagraph (A) shall be allowed as a deduction under subsection (a) to the extent that the aggregate of such contributions does not exceed the excess of— ‘‘(I) 60 percent of the taxpayer’s contribution base for the taxable year, over ‘‘(II) the aggregate amount of contributions taken into account under subparagraph (A) for such taxable year.’’. (2) COORDINATION WITH OTHER LIMITATIONS.— (A) IN GENERAL.—Clause (iii) of section 170(b)(1)(G) is amended— (i) by striking ‘‘SUBPARAGRAPHS (A) AND (B)’’ in the heading and inserting ‘‘SUBPARAGRAPH (A)’’, and (ii) in subclause (II), by striking ‘‘, and subpara- graph (B)’’ and all that follows through ‘‘this subpara- graph’’. (B) OTHER CONTRIBUTIONS.—Subparagraph (B) of sec- tion 170(b)(1) is amended— (i) by striking ‘‘to which subparagraph (A)’’ both places it appears and inserting ‘‘to which subparagraph (A) or (G)’’, and (ii) in clause (ii), by striking ‘‘over the amount’’ and all that follows through ‘‘subparagraph (C)).’’ and inserting ‘‘over— ‘‘(I) the amount of charitable contributions allowable under subparagraph (A) (determined without regard to subparagraph (C)) and subpara- graph (G), reduced by ‘‘(II) so much of the contributions taken into account under subparagraph (G) as does not exceed 10 percent of the taxpayer’s contribution base.’’. (c) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 2025. SEC. 70426. 1-PERCENT FLOOR ON DEDUCTION OF CHARITABLE CON- TRIBUTIONS MADE BY CORPORATIONS. (a) IN GENERAL.—Section 170(b)(2)(A) is amended to read as follows: ‘‘(A) IN GENERAL.—Any charitable contribution other- wise allowable (without regard to this subparagraph) as a deduction under this section for any taxable year, other than any contribution to which subparagraph (B) or (C) applies, shall be allowed only to the extent that the aggre- gate of such contributions— ‘‘(i) exceeds 1 percent of the taxpayer’s taxable income for the taxable year, and ‘‘(ii) does not exceed 10 percent of the taxpayer’s taxable income for the taxable year.’’. (b) APPLICATION OF CARRYFORWARD.—Section 170(d)(2) is amended to read as follows: ‘‘(2) CORPORATIONS.— ‘‘(A) IN GENERAL.—Any charitable contribution taken into account under subsection (b)(2)(A) for any taxable year which is not allowed as a deduction by reason of 26 USC 170 note. Effective date.