In 1997, the IRS issued final regulations providing that a domestic LLC wholly owned by single owner could be disregarded as a entity separate from its owner and its operations treated as a branch of its owner. Consistent with those rules, in Announcement 99-102, the IRS provided that an owner that is exempt from taxation under Code §501(a) must include, as its own, information pertaining to the finances and operations of a disregarded entity in its annual information return (Forms 990, 990-EZ, 990-T, and 990-PF).
Well, it is has only taken 15 years, but the IRS is know acknowledging in Notice 2012-52 that it will treat as a charitable contribution to a U.S. charity a contribution to a disregarded entity wholly owned by the U.S. charity.
