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contributions of Foreign stock to Donor Advised Fund (DAF)

charleslye
Level 2

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

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1 Comment 1
BobKamman
Level 15

It's also traded on the US OTC market (ZFSVF; also ZURVY; these are ADR's, so representing a fraction of the Swiss shares).  What's interesting is that almost all of their investments are American companies:

https://www.otcmarkets.com/filing/html?id=16864047&guid=m05-kKqdzR7fJth

I'm not aware of any rule against donation of foreign stocks.  Same thing as donation of US stocks that mostly own shares in foreign companies, right?