The IRS will treat a charitable contribution to U.S. disregarded single-member LLCs that are wholly owned and controlled by organizations described in IRC Sec. 170(c)(2) , as a contribution to a branch or division of the U.S. charity. As a result, the U.S. charity is the donee organization for purposes of the substantiation and disclosure requirements required by IRC Sec. 170(f) . The IRS encourages the charity to disclose in the acknowledgement, or another statement, that the single-member LLC is wholly owned and treated as a disregarded entity. This guidance became effective 7/30/12, but may be relied on prior to its effective date if the limitation period for refunds or credits has not expired. Notice 2012-52, 2012-35 IRB .