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IRS's recent pronouncement that gifts to U.S. charity-owned disregarded limited liability companies will be tax deductible clears up long-standing questions about donations of real property to charities, practitioners say. Before Notice 2012-52, taxpayers had no definitive guidance as to whether a charitable contribution to a disregarded LLC owned by a charity would entitle the donor to a charitable deduction. Resolution of this issue offers benefits to charities that prefer not to hold title to certain types of property, such as real estate, but instead want to hold the property through a single-member limited liability company, McGuireWoods tells clients.
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