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
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?
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