Finally, IRS recognizes deductibility of gifts to single member LLCs

After many years of confusion and refusal to rule, the IRS has said that it will recognize the deductibility of a charitable contribution to a single member limited liability company in which the sole member is a U.S. charity. (Notice 2012-52.)

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April 21, 2025

Those old enough to remember what it meant to say a story appeared “above the fold” on the front page of a newspaper may appreciate this story. People used to want to place stories above the fold because readers would at least glance at the story in the top half of the page that was visible when they picked up the paper before they looked at stuff that was below the fold and not immediately visible.

The printed version of the Philadelphia Inquirer had a four column picture and article about Pope Francis on the day after Easter that was written and printed before the Pope had died but seen by morning readers after his death had been widely reported. The fold divided the two-line headline so only the top line was visible. The top line said: “Pope meets Vance, then”

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Finally, IRS recognizes deductibility of gifts to single member LLCs

Finally, IRS recognizes deductibility of gifts to single member LLCs