Income offset by charitable deduction?

[chris]

Participant has approx. 4 MIL in PSP. Particpant also owns real estate (low basis) worth approx. 4 MIL. Participant plans to take a distribution of entire 4 MIL in same year that participant plans to donate the 4 MIL of real estate to charity. Participant believes it will be a wash; however, I think the charitable deduction rules may allow for up to 50% of AGI deduction (will need to verify). Anybody see any issues with this? Alternative Minimum Tax issues? Assuming the distribution is per a distributable event under the plan document I don't think the PSP is impacted at all.

[mbozek]

Taxpayer can deduct maximum 50% of AGI as a charitable contribution made in cash in any tax year. Contribution of capital gains property is limited to 30% of AGI. IRC 170(b). Remainder of contribution is carried over for 5 succeeding tax years. Also itemized deduction including chartiable contributions will be reduced by 3%. The participant need to consult a tax advisor.