Long-awaited notice allows individual and corporate
donations made directly to a single-member LLC to be treated as
donations made to the parent 501(c)(3) organization.
Many Section 501(c)(3) organizations establish single-member
LLCs (SMLLCs) to conduct certain activities or to hold real estate
or other assets. A common reason for establishing an SMLLC is to
provide liability protection for the parent 501(c)(3) organization
with respect to the SMLLC's activities. These SMLLCs are
generally treated as "disregarded entities" for federal
tax purposes, and their income and expenses are reported directly
on the Forms 990 filed by the parent organizations. Although the
Internal Revenue Service (IRS) has previously held that private
foundation grants to SMLLCs are treated as grants made directly to
their 501(c)(3) parents, see I.R.S. Gen. Info. Ltr. 2010-0052,
(June 25, 2010), available here, it has, until now, declined to hold that
contributions made directly to SMLLCs by
