Sponsorships are their own kettle of fish, assuming you're talking about corporate/org sponsorships, and they almost always dovetail with UBIT. But assuming that part is being handled correctly, there's no problem with what you've laid out.
Thank you,
Isaac Shalev
Data Strategy Expert
Sage70, Inc.
(917) 859-0151
isaac@sage70.com
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Original Message:
Sent: 7/16/2025 1:21:00 PM
From: Tioga Anderson
Subject: RE: Events - Charitable Portion Minimum
Ok we currently have events where just buying a ticket to golf or attend is treated as "proceeds to benefit" and they receive a receipt thanking them for signing up and supporting the program/fund it benefits, and it notes that there is no charitable component. However, sponsorships are also available to purchase and they are treated as charitable, less the number of golf tickets (if any) that they receive with the sponsorship. Anyone who registers is also prompted to make an additional charitable contribution. Is there any issue with this setup?
Thanks for the insights.
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Tioga Anderson
East Stroudsburg University Foundation
tanderson@esufoundation.org
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Original Message:
Sent: 07-16-2025 10:04 AM
From: Isaac Shalev
Subject: Events - Charitable Portion Minimum
Yes, I think you can set such a policy, but be prepared for edge cases where, for example, you want to have broad general attendance, so you set low ticket prices, but also have high-dollar contribution opportunities available to your supporters.
Regarding the size of the charitable component that obligates a QPQ, the overall cost of the ticket must exceed $75, and the noncharitable portion must exceed the lesser of 2% of the contribution or $13.60 (for 2025).
In terms of how to determine the FMV, the IRS is broadly permissive in this area as regards to method, but not outcome. The FMV is the price the goods/services would sell for on the open market. The best practice is to choose a method, document it, and apply it consistently. 'Cost-plus' can be an acceptable method, so long as the 'plus' portion is justified, by, for example, typical pricing formulas for similar for-profit events. It can't just be a guess. Looking to pricing of similar events directly is my preference for establishing FMV.
If you want to do a 'proceeds to benefit' event, you do not have to determine FMV or find some way to set FMV equal to the ticket price. You can simply charge what you charge, and do not promise a tax deduction, and do not provide a receipt with any language about tax deductibility. Note that there can be UBIT implications for these types of events if they fall outside of the normal scope of your nonprofit mission and operations.
Thank you,
Isaac Shalev
Data Strategy Expert
Sage70, Inc.
(917) 859-0151
isaac@sage70.com
Schedule a 30-minute consultation now:
Original Message:
Sent: 7/16/2025 9:59:00 AM
From: Tioga Anderson
Subject: RE: Events - Charitable Portion Minimum
Thanks Issac. Yes, we still receipt all events and note that there is no charitable component on the receipt. But am I ok to set a set a general rule for our Org that says unless you set the ticket price high enough to warrant it ($100 or move above FMV), we'll treat the event as proceeds to benefit event and issues receipts noting the $0 deductible amount? If I believe the ticket price is above FMV by any amount, no matter how minuscule, are we obligated to treat it as charitable and issue a receipt? Say an event cost $150 to attend - costs about $70 per person for the entire event, plus a ~$15 giveaway. To me the FMV of this ticket is $115 ($70 per person, but a fair market transaction would aim to make a profit so call it $100 to attend plus the $15 giveaway). If you can reasonably argue that $115 is the FMV, you could just as easily argue that $150 is a reasonable fair market price and set the charitable amount to $0. The price should be at least $215 to be worth treating them all as charitable donations.
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Tioga Anderson
East Stroudsburg University Foundation
tanderson@esufoundation.org
Original Message:
Sent: 07-16-2025 08:43 AM
From: Isaac Shalev
Subject: Events - Charitable Portion Minimum
Hi Tioga,
The IRS obligates charities to issue disclosure statements on solicitation or on receipt for quid pro quo contributions of over $75, unless the goods/services received by the donor are of insubstantial value or only an intangible religious benefit is provided.
What most orgs will do is one of the following:
- Ensure that the benefits provided are insubstantial (under the lesser of $13.60 or 2% of the contribution)
- Set ticket prices whose charitable component is high enough to warrant the FMV effort
- Run events as "proceeds to benefit" events which are not deductible to the donor at all
Note that there are a lot of things the IRS allows, eg not issuing tax receipts for non-QPQ contributions, or issuing disclosure statements on solicitation but not on receipt, that are not very good stewardship practices, because even though the IRS may not require your org to issue a receipt, they will require the donor to have obtained one to substantiate their tax deduction.
Thank you,
Isaac Shalev
Data Strategy Expert
Sage70, Inc.
(917) 859-0151
isaac@sage70.comSchedule a 30-minute consultation now:
Original Message:
Sent: 7/15/2025 8:14:00 PM
From: Tioga Anderson
Subject: Events - Charitable Portion Minimum
Hello,
Do any of you have rules/guidelines for events on when issuing charitable receipts are warranted? We've had events in the past where we've been sending receipts noting charitable portions of less than $50, and in many cases less than $10. The $10 and under I've already eliminated and just said we're treating them as non charitable. I'd like to say that Advancement Services will only go through the legwork required to calculate FMV and set up the receipting if you expect the charitable portion will be $100 or greater. Just curious if others have rules/guidelines like this.
Thanks
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Tioga Anderson
East Stroudsburg University Foundation
tanderson@esufoundation.org
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