Great discussion!  I agree with the theory that most donations are not Sec 162 items.

However, technically, my take is that because the 8995 instructions clearly state that charitable contributions MUST reduce QBI and the 1120S QBI Flowchart states basically the same thing (the use of the term “MAY” seems to be a qualifier that the list is not all-inclusive, not that some of the listed expenses may not be attributable to a T or B), S-corp and P/S donations still need to reduce QBI.

IRS definitely needs to clarify this, though!