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Contributions to Disregarded Entities

Images-3Are contributions deductible for income and transfer tax purposes when they are made to a disregarded entity that is wholly owned by a charity exempt by section 501(c)(3)? The Tax Section of the New York State Bar Association wrote a letter to tax officials at the treasury and the IRS to determine the answer to this question.

The Tax Section attached a 55-page report to the letter that argued that the contributions should be deductible. To see some of the arguments in more detail, please visit the link below.

See NYSBA Seeks Formal Guidance on Contributions to Disregarded Entities, Charitable Planning.com, Jan. 19, 2012.

Special thanks to Jim Hillhouse (Professional Legal Marketing  (PLM, Inc.)) for bringing this article to my attention. 

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