Deductibility of charitable contributions to LLCs wholly owned by charitable organizations *

USA - August 9 2012
On July 31, 2012, the Internal Revenue Service (the IRS) issued Notice 2012-52 (the Notice), providing long awaited confirmation that a charitable contribution to a limited liability company that is wholly owned by a charitable organization, and classified as a disregarded entity for U.S. federal income tax purposes (an SMLLC), will be treated as a contribution to a branch or division of the charitable organization.

Co-authors: Elizabeth M. Mills, Jacob I. Friedman, Stuart L Rosow, Amanda H Nussbaum.