Charities’ Expanded Use of LLCs

Charitable organizations now have more flexibility to use single member limited liability companies (“LLCs”).  In Notice 2012-52, the IRS stated that contributions to a single member LLC that is wholly owned by a section 501(c)(3) organization will be treated as a contribution by the donor to the parent charitable organization.  As an example of the impact of this Notice, charities will be able to use a wholly-owned LLC as a fundraising organization without concerns over the deductibility of contributions to the LLC.  The Notice is a welcome pronouncement for the tax-exempt organization community.