Donor-advised fund funded with the appreciated position
Dec 31 hard stopDonating the most-appreciated shares of the concentrated position accomplishes two goals at once: a FMV charitable deduction at the 37% rate and a tax-free trim of the concentration. Bunching into a DAF fixes the high-bracket deduction now while preserving grant flexibility, and the existing $22K carryforward is used before it expires. Cash giving would forfeit the embedded-gain avoidance.
Assumes a ~$100K–$150K gift of long-term appreciated shares from the concentrated position, deductible at FMV within the 30%-of-AGI ceiling for capital-gain property (§170(b)(1)(C)) at the 37% marginal rate, plus the avoided ~23.8% embedded gain. The unused $22K 2025 carryforward is absorbed first.
Cash giving forfeits the embedded-gain avoidance; the $22K carryforward risks expiring unused.
$37K–$56K saved, the carryforward absorbed, and the concentrated position trimmed tax-free.