My US client wants to move foreign stock of a public company in Switzerland (ZURN) to his Morgan Stanley DAF in 2023.  The stock has appreciated over years and is worth over $2 million with a cost basis of $1 million.  Question is if a donation to the DAF of overseas stock would be challenged by the IRS for a tax write-off on the Market Value (instead of the cost basis)? I reviewed PUB 526 don't see anything preventing the write-off under "Contributions your Can't Deduct" so would they still challenge the step up in basis?

Charles Lyke

Thanks you for any feedback