Charitable contribution deductions for trusts and estates are subject to unique rules that are discussed in Private Letter Ruling 201611002.  The conclusions of this ruling aren’t at all surprising, but it does provide a good review of the topic, including the differences between “accounting” and “tax” definitions for trusts.

The trust was the beneficiary of an IRA of a decedent who established the trust.  The trust provided that the IRA is to be distributed to a charitable organization.  That raises a tax concern since the trust is a taxable entity and the IRA, rather than being left directly to the tax exempt charity, had been left to the trust which was to distribute the IRA to that organization.