This has to do with charitable contributions.
In 2026 (not 2025), individuals making charitable contributions will have a new 1/2% floor which disallows that percentage of AGI (adjusted gross income). This is the first time contributions have a disallowed portion. It is best explained using the medical deduction on the Schedule A that disallows 7.5% of AGI for unreimbursed medical costs. I have explained this to many of you int the past.
It is advised to consider a donor-advised fund. It is a charitable vehicle within a section 501(c)(3) public charity allowing the donor to make a gift, take an immediate deduction and have persuasive recommendation for future grants made from the DAF. It is not like a private foundation which requires a minimum annual distribution. The DAF has no such requirements and can allow the funds to build up for many years.
If interested, please contact a brokerage house.