IRS Allows Charitable Contributions To Disregarded Entities

December 2012

In this article, Upton and Merino discuss Notice 2012-52, which confirms the deductibility for income tax purposes of charitable contributions to domestic single-member limited liability companies owned by U.S. charities. They explain the basis for the notice in existing law and Treasury guidance and discuss remaining questions, including the treatment of charitable contributions to disregarded entities for gift and estate tax purposes, and the deductibility of charitable contributions to foreign disregarded entities owned by U.S. charities.

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