I would respectfully disagree with that.

Final regulations state that "deductions attributable to a trade or business are taken into account for purposes of computing QBI to the extent that the requirements of section 199A and this section are otherwise satisfied."  That subsection then goes on to specify deductions for 1/2 SE tax, SE health insurance, and qualified retirement plan contributions are to be taken into account.

As explained on pages 43 and 44, the Treasury Department and IRS are relying on existing code sections that govern the respective deductions to determine whether such deductions are attributable to the conduct of a trade or business.  Those deductions that are specifically listed have a history of being treated as such even prior to the enactment of §199A.  Charitable contributions, on the other hand, are merely flow-through items from an RPE and not attributable to the conduct of a trade or business - none of the limitation based on business income, at-risk rules, etc. even apply.