The IRS released Notice 2012-52 recently, which held that if a donor makes a contribution to a charity owned single-member LLC then that donation would be treated for tax purposes as if the donor made the donation directly to the Section 170(c)(2) charity. The notice explained that the contribution is considered a gift to a charity for “disclosure requirements for quid pro quo contributions under Sec. 6115.” The percent limitations also applies to the contributions. The notice also mentioned that charities might want to consider providing some type of notice that the SMLLC is either owned by the charity or treated as a disregarded entity.
See Sally P. Schreiber, Notice Permits Charitable Contributions to Single-Member LLCs, Journal of Accountancy, Aug. 6, 2012.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.
