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Say John has three kids, Alice, Bob, and Carl, and sets up an ESA for each child. Also, John's income is too high to contribute to the ESA himself.

Can he have a non-deductible corporate contribution to each ESA, $2,000 for each child?

If so, is there a tax liability for anyone by doing that? (either him, the children, or the corporation).

If no, does this just become a non-deductible business expense, i.e. coming out of bottom line profits?

Seems like an easy way to send an extra $2,000 per child to an employee (assuming they have education expenses to send it toward).

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Not sure how authoritative it is, but according to this site, yes:

Can a corporation, partnership or other non-living entity make the contribution to an ESA?

Yes. The tax law does not restrict the ability to make contributions to living individuals. Corporations and other entities may make contributions without regard for the usual donor income limit.

However, the same site indicates that you can just give the child the $2K and have them contribute to their own ESA, so yes, the income limit is pretty easy to get around.

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