If you were surprised to read about the ripple effect of a seemingly small change in the U.S. Postal Service regulations late last year, you were not alone! Here’s what you need to know, including potential remedies for you whose 2025 charitable deductions may be impacted by the rule change.
What’s the background with the IRS?
Under long-standing IRS guidance, a charitable contribution is generally considered “made” for tax purposes when the donor irrevocably parts with control of the gift. For contributions made by check and sent through the mail, the IRS has traditionally treated the date of the U.S. Postal Service postmark as the date of the gift, even if the charity receives the check later. This approach is reflected in IRS Publication 526 and generally parallels the broader “mailbox rule” under Internal Revenue Code Section 7502, which treats certain documents and payments as timely based on their postmark date rather than the date of receipt.
Okay, so if this is not an IRS issue, what happened?
In November 2025, the U.S. Postal Service (not the IRS) changed how postmarks are applied. Effective December 24, 2025, the official postmark date is now defined as the date of the first automated processing scan at a USPS processing facility, rather than the date a letter is dropped in a mailbox or handed to a clerk at a local post office. As a result, mail deposited on December 31, 2025, may not have actually received a postmark until several days later, especially around the holidays. This change took many people by surprise and created considerable confusion, prompting the USPS to issue a “facts and myths” circular.
So what’s this got to do with the IRS?
Because the IRS’s practices continue to rely on the postmark to establish the date of a mailed charitable gift, this change can cause a contribution that you intended to deduct for 2025 to be treated as a 2026 contribution if the postmark reflects a January processing date.
If you got caught up in this change, is the client totally out of luck for a 2025 charitable deduction?
Not necessarily. Remember, the underlying IRS rules governing charitable contribution timing have not changed. Publication 526 still requires you to “substantiate”—meaning document—the date of their gift, and the IRS continues to look at objective evidence to substantiate and determine when the contribution was made. What has changed is the ability to rely entirely on an ordinary envelope postmark as proof of a year-end gift. (Advisors should understand that the statutory mailbox rule in Section 7502 is primarily directed at tax filings and payments to the IRS, but in practice the IRS uses similar concepts when evaluating the timing of charitable gifts, particularly where the postmark is the primary evidence of mailing.)
Okay, it sounds like all is not lost. What should I do?
If you are caught up in this rule change at the end of 2025, the first step is to gather and preserve any alternative proof that establishes when the gift was actually mailed. Documentation such as a USPS Certificate of Mailing, a certified or registered mail receipt, or a manually applied postmark or postage validation imprint obtained at the retail counter can help demonstrate that the donor relinquished control of the gift before year-end, even if the automated processing postmark is later. Even when you have such postal documentation, contemporaneous records such as copies of the check, your notes, and any correspondence with the charity should also be retained in the event the deduction is questioned. In other words, you may be able to build a case to support your deduction for 2025.
What should you do for 2026 and beyond?
Advisors should counsel you on how to avoid this issue going forward. Electronic giving methods such as online donations, ACH or wire transfers, and completed transfers of publicly traded securities provide clearer and more immediate timestamps for deduction purposes and do not depend on postal processing practices.
How can the Community Foundation help?
Reach out to our team early in the year! Many people find themselves scrambling at year‑end to make charitable donations, and the recent postal rule changes serve as a great reminder of why early planning matters. Establishing a donor‑advised fund at the Community Foundation allows you to make your tax‑deductible contribution well before December 31, securing any applicable charitable deduction. Then, you can take your time recommending grants from your donor‑advised fund to your favorite charities whenever you choose.
The team at the Community Foundation is honored to serve as a resource and sounding board as you build your charitable plans and pursue your philanthropic objectives for making a difference in the community. This article is provided for informational purposes only. It is not intended as legal, accounting, or financial planning advice. Please consult your tax or legal advisor to learn how this information might apply to your own situation.