The purpose of this document is to provide guidance regarding the acceptance of gifts-in-kind and to define related responsibilities.
May, 2023Responsible Office
Gifts-in-kind will be accepted if they are going to used or exhibited by the University or sold to provide funds for other purposes.
Gifts-in-kind are donations of real estate or tangible personal property, including land, antiques, rare books, art, equipment, inventory, livestock, and software.
In accordance with Responsibility Center Management and related Internal Control Governance as defined in Policy 2701, Internal Control Policy, the accepting School/Center has responsibility for compliance with this policy.
Development and Alumni Relations (DAR) in collaboration with Gifts and Investment Services (GIS) is responsible for collaborating with the accepting School/Center and providing guidance and compliance oversight.
The responsibilities vary based on the categorization of the gift, as follows:
GIS, in collaboration with the accepting School/Center, will coordinate the provision of all appropriate documentation, including useful life estimates, to Property Management in the Office of the Comptroller to ensure proper recording of the assets.
Tangible property and real estate employed in support of the University’s mission, including the generation of revenue, with an economic life greater than one year are required to be valued, if the anticipated value exceeds $25,000. Such gifts-in-kind are to be added to the Property Management System in the fiscal year in which they are received.
DAR and GIS must approve all gifts of tangible property or real estate held for sale prior to acceptance. Gifts-in-kind accepted and held for sale must be recorded at fair market value if they have not been sold as of June 30 of the fiscal year of receipt. The University generally does not accept gifts-in-kind that are intended to be used for less than three years. If a gift-in-kind is disposed in whole or in part via sale, transfer, consumption or otherwise within three years of the date of receipt, the accepting School/Center, in collaboration with DAR and GIS, must report the disposition to the Office of Corporate Tax, Compliance and Payroll in the Office of the Comptroller. If required, Form 8282 Donee Information Return will be prepared and remitted to the Internal Revenue Service. If a gift-in-kind is transferred to a successor donee within three years of the date of receipt, the University will give the successor donee information as required by federal tax law.
The Office of the Curator should be notified of all proposed artwork and collection donations intended to be held for public exhibition, education, or research for review and approval. See the Policy 2276, Collectible Assets – Accepting Gifts of Artwork.
Accepted gifts held for public exhibition are not recorded as financial assets for financial statement purposes.
Real Estate donations must be approved by DAR and GIS, in consultation with the Office of General Counsel. See Policy 2231, Gifts of Real Estate.
Generally accepted accounting principles require the University to determine and record the fair value of gifts-in-kind in the fiscal year received unless they are held for public exhibition. A timely independent appraisal is required to support recorded values for real estate.
To minimize costs to the University, an appraisal or other form of substantiation should be obtained from the donor. If the accepting School/Center in collaboration with DAR and GIS determine that the donor’s substantiation documentation is timely and reasonable it may be used to record the value of the gift-in-kind.
If the donor’s substantiation is not obtained or it is not timely or reasonable, the accepting School/Center, in collaboration with DAR and GIS, must obtain an appraisal or other form of substantiation so that the gift may be recorded at this value in the fiscal year received.
As a general rule an appraisal or other form of acceptable substantiation is considered timely if it is dated within 12 months of the contribution date. Planning for gift acceptance should consider the donor’s plans for obtaining and providing value substantiation to the accepting School/Center. The appraisal generally must be completed by an independent expert in the field.
Recorded values for new equipment may be supported by a recent invoice, catalog inventory listing, or other retail listing. Recorded values for used equipment may be supported by listings from eBay, Craig’s List, or other available sources.
The contribution date is the date a gift-in-kind is physically delivered, or in the case of real estate, when the deed in signed.
There may be circumstances in which determining a timely and reasonable value of a gift in the fiscal year received will be difficult or costly. The accepting School/Center, in collaboration with DAR and GIS, and with approval by the Vice President for Finance and Vice President of Development, may defer valuation to the following fiscal year if the anticipated value will not be material to the current year GAAP financial statements.
The University will not report a value for a gift-in-kind on a gift receipt. See Policy 2202, Gift Receipts. The University gift receipt will provide a description of the asset received and the date of receipt. Donors are required to obtain substantiation of value to support any deductions taken on their personal tax returns.
A value, if any, may be noted for donor record keeping and recognition purposes only.
Donors of gifts-in-kind may be required to fie Form 8283, Noncash Charitable Contributions, with their federal income tax returns. The University will complete and sign the Donee Acknowledgement section of a Form 8283 provided to it by a donor.
The University is required in most cases to file Form 8282, Donee Information Return, with the Internal Revenue Service if gifts-in-kind are sold, exchanged, or otherwise disposed of within 3 years after the date the University received the gift. The University will give a copy of Form 8282 to the original donor.