“The UK should not aspire to a U.S. model of philanthropy and tax incentives — it is not replicable and is a unique product of social, political and historical factors,” a report released by the UK-based Charities Aid Foundation back in February argues.

The report, Give Me a Break (20 pages, PDF), argues that while there are things the UK can learn from the U.S. model of philanthropy, there are features of it that the UK, which has a well-organized welfare state, cannot and should not replicate. “For instance,” the report notes, “the U.S. charitable deduction is inherently biased toward those [with] higher incomes….Similarly, donations in the U.S. go disproprtionately to religious causes and education (45 percent in total).”

The report notes that 32% of US giving goes to religious causes while in the UK it is 17%.