I read an interesting US article entitled “Where Generosity and Pride Abide: Charitable Naming Rights” by William A. Drennan.  It discusses the US IRS position on valuing naming rights and asks whether that position should change.

Here is the conclusion to the article

This Article‘s proposal to eliminate the tax deduction for the naming portion of a transfer to charity will (1) advance horizontal equity by treating naming philanthropists like other donors who receive a return benefit from a charity; (2) improve taxpayer confidence in the fairness of the U.S. tax system, and may in turn improve voluntary compliance; and (3) free charitable fundraisers from the current duplicative milieu in which the charity advertises naming rights like a commodity, enters into a contractually binding agreement with the benefactor, and then proclaims that the naming right was not a return benefit to the philanthropist.309 The current situation compels our charities to issue dubious documents and make suspect statements to comply with the tax laws and accommodate benefactors.310 This Article proposes a viable approach for implementing the fundamental claim consistent with the current regulatory structure for valuing charitable gifts and documenting donations.
Correcting the tax treatment for charitable naming arrangements may have broad beneficial effects. The ability of wealthy philanthropists to buy naming rights and deduct the entire amount transferred may be triggering profound adverse consequences in the charitable world. Philanthropists evaluating potential charitable recipients may choose the charity that can sell the best publicity package, rather than the charity with the best plan for helping the poor or cleaning the environment.311 Benefactors seeking to fund education may choose to have their names emblazoned across prestigious university campuses312 while ignoring petitions from lower-ranked institutions. Patrons trying to select a charitable cause may buy naming rights from the symphony constructing a grand new edifice, rather than contributing to help stock the shelves at the food pantry.313 Current law treats donors the same whether or not they indulge their propensity for pride when acting generously.
Furthermore, charities may structure their activities to offer tax-advantaged naming rights. Rather than repairing the boiler and patching the roof, the charity may decide to build a new structure and sell naming rights to fund it. A consultant observes that billion dollar fundraising campaigns abound in the new naming rights era, and he asks whether these campaigns are undertaken because they are needed or because they are possible.314 These broader issues highlight that ending the special exception for the naming portion is vital.

You can read the full paper.

Here is a recent CRA letter dealing with naming rights.