Benevolence funds are sorely in demand. Sometimes religious institutions receive contributions designated for a benevolence fund along with a recommendation or direction as to who should receive support. Are these tax-deductible gifts when made to a qualified charity? Some institutions record them as such without a thought. Others treat the gifts just like a contribution made directly to the individual, which is not tax deductible. In this example, there are two questions: whether the designation of purpose is permissible and whether there has been a designation of recipient that is permissible. With respect to the latter, the rule of thumb is that the donor’s intent should determine whether the transfer should be characterized as a tax-deductible contribution to a church or a nondeductible transfer to an individual. But proper characterization of the gift is nuanced enough that it makes sense to discuss with church-state counsel how your benevolence fund is structured and whether particular types of donations qualify as tax-exempt. Critical questions will be whether the donor’s recommendation is advisory only, the church retains full control of the donated funds and discretion as to their use, and the donor understands both.