Updated July 28, 2026. Quick answer: Appreciated property other than publicly traded stock, given to a non-operating private foundation, is deductible at basis rather than fair market value under IRC §170(e)(1)(B)(ii). The exception for “qualified appreciated stock” preserves full value — but it is cut off by a cumulative family limit most donors never hear about until they hit it.
The basic rule and its exception
| Gift to a non-operating private foundation | Deduct |
|---|---|
| Publicly traded stock (qualified appreciated stock) | Fair market value |
| Real estate, closely held stock, art, other property | Basis |
| Cash | Face amount |
The qualified-appreciated-stock trap. Under IRC §170(e)(5)(C), the exception stops applying once the donor’s cumulative contributions of a given corporation’s stock exceed 10% of the value of all that corporation’s outstanding stock, counting gifts by the donor’s family. For a founder giving shares in their own company to their own foundation, that ceiling is reachable — and everything past it drops to a basis deduction, which for founder stock is often close to nothing.
Not every private foundation is treated this way
Private operating foundations, and conduit foundations that redistribute contributions within the required period, get public-charity treatment for the AGI ceilings under §170(b)(1)(A)(vii). So “private foundation” is not one category for this purpose, and which kind you have changes the answer.
If the goal is to give appreciated property and keep the full deduction, a public charity or a donor-advised fund preserves fair market value where a private non-operating foundation does not.
No dollar figures appear here, and that is deliberate. The QCD annual cap is inflation-indexed and the figure printed in IRC §408(d)(8)(A) is the original un-indexed amount, which the statute will keep reciting forever. AGI ceilings are percentages, not amounts. Take current dollar limits from the IRS for the year in question, never from an article.
Sources
IRC §170(b)(1)(A), (b)(1)(C), (b)(1)(D), (b)(1)(G), (b)(1)(I) and (d)(1); §170(e)(1) and (e)(5); §170(f)(11) (appraisal); §68 as amended; §408(d)(8) (qualified charitable distributions); §4966(d)(2) (donor-advised funds); §664(d)(1) and (d)(2) (charitable remainder trusts). Amendments from P.L. 119-21. IRS Publication 505 (2026) for the 0.5% floor’s first application year. All read July 2026.
This states what the cited authority says. It is not tax advice, and retirement-plan design turns on facts about your business and your other entities that no page can see. Every dollar limit referenced here is indexed and changes annually.