lower rate, the charity will receive less than the computed amount, but the donor will not lose any of his initial tax deduction.The UK and the US have been described as “two nations, separated by a common language”. Despite their many shared traits, there remain numerous differences between them. One such difference can be seen in the area of philanthropy: in recent years, charitable giving as a percentage of gross domestic product by Americans has more than doubled that of the English.

Why should it be that, say, wealthy New Yorkers are more interested, on average, than their London counterparts in pursuing philanthropic objectives? While the sociologist or cultural anthropologist may articulate a litany of underlying causes, the explanation may, at least in part, be tied to differences in tax regimes: the US tax system encourages and rewards charitable giving in various ways that the UK system simply does not. Consider, for example, the US treatment of gifts of tangible personal property and so-called ‘split interest’ gifts made in trust.