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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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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?
