The IRS recently announced that a contribution to a domestic LLC that is wholly owned and controlled by an IRC ? 501(c)(3) charitable organization will be treated as if the contribution were made directly to the charitable organization, provided that the LLC has not elected to be taxed as a corporation. Although the IRS had previously provided guidance to public charities and private foundations as to the tax treatment of operating through such single-member LLCs, the July 31, 2012 release of Notice 2012-52 was the first guidance given to individual and corporate contributors as to the deductibility of their contributions. Left unaddressed, however, is the tax treatment of a contribution to a single-member, ?disregarded entity? LLC organized in a foreign jurisdiction.
To see the announcement, click here: Notice 2012-52
Source: http://www.jdsupra.com/post/documentViewer.aspx?fid=7db9df33-414d-4076-a3c4-750f5dcf96d1
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