Friday, August 03, 2012

IT IS OKAY TO MAKE A CHARITABLE CONTRIBUTION TO AN LLC WHOLLY OWNED BY A §501(C)(3) ORGANIZATION, IF YOU WERE WORRIED ABOUT THAT

In 1997, the IRS issued final regulations providing that a domestic LLC wholly owned by single owner could be disregarded as a entity separate from its owner and its operations treated as a branch of its owner.  Consistent with those rules, in Announcement 99-102, the IRS provided that an owner that is exempt from taxation under Code §501(a) must include, as its own, information pertaining to the finances and operations of a disregarded entity in its annual information return (Forms 990, 990-EZ, 990-T, and 990-PF).
Well, it has only taken 15 years, but the IRS is now acknowledging in Notice 2012-52 that it will treat as a charitable contribution to a U.S. charity a contribution to a disregarded entity wholly owned by the U.S. charity.
Notice 2012-52
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