April 2014
Intermediate to advanced
176 pages
4h 21m
English
book
Tax Planning and Compliance for Tax-Exempt Organizations, Fifth Edition 2014 Cumulative Supplement
by Jody Blazek
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CHAPTER 24
Deductibility and Disclosures
§ 24.1 Overview of Deductibility
*(b) Limitations on Deductions
§ 24.2 Substantiation and Quid Pro Quo Rules
§ 24.1 Overview of Deductibility
p. 748. Add to list of organizations that are eligible to receive deductible charitable contributions:
6. Contribution to disregarded single-member LLC treated as made to charity that owns it.
p. 749. Add IRS explanation of new item 6 after first paragraph:
The IRS announced that, if all other requirements of the tax code1 are met, a contribution to a U.S. disregarded single-member limited liability company (LLC), wholly owned and controlled by a U.S. charity, will be treated as a charitable contribution to a branch or division of the U.S. charity.2 Since 1999 when the IRS announced that the revenues and activities of a tax-exempt organization's LLC could be treated as that of the organization itself, they did not take a position on the character of funds donated to the LLC. Now it has been clarified that the U.S. charity is the donee organization for purposes of the substantiation and disclosure requirements discussed in this chapter. The IRS recommends that donor acknowledgments disclose that the single-member LLC is wholly owned by the U.S. charity and treated by the U.S. charity as a disregarded entity. The LLC may not, however, be listed in the IRS Exempt Organization Select Check.
(a) Contribution Defined
p. 750. Add at end of page:
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