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.) Generally, a single member limited liability company is considered a “disregarded entity” and is treated in the same manner as a sole proprietorship, branch, or division of the owner. A U.S. charity that wholly owns or controls a disregarded entity is required to treat the operations and finances of the disregarded entity as its own for tax and information reporting. Its income and expense are consolidated with the parent charity, and whether or not...