Gifts blocked by the ceiling carry to the next year
What the document says“Any charitable contribution taken into account under subsection (b)(2)(A) for any taxable year which is not allowed as a deduction by reason of clause (ii) thereof shall be taken into account as a charitable contribution for the succeeding taxable year”
The section rewrites section 170(d)(2) of the Internal Revenue Code of 1986 so that a contribution blocked by the 10 percent ceiling counts as a contribution for the next taxable year, with that year's own contributions counted first. Where a year already carries a contribution forward, the rule is read as covering amounts blocked by the floor as well as by the ceiling.
What the document actually says“Any charitable contribution taken into account under subsection (b)(2)(A) for any taxable year which is not allowed as a deduction by reason of clause (ii) thereof shall be taken into account as a charitable contribution for the succeeding taxable year”
A gift blocked by the ceiling is not lost. It counts as a gift for the next tax year.
That year's own gifts are counted first. Only then does the carried gift get its turn. The floor is treated the same way in some years.
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