IRS Attacks on Charitable LLCs Expand to Other Donations

IRS Attacks on Charitable LLCs Expand to Other Donations

June 29, 2026

TAX NOTES FEDERAL

The IRS has devoted lots of attention lately to taxpayers donating partial interests in so-called charitable limited liability companies.  It believes, right or wrong, that some situations are merely attempts to transfer assets on paper only, claim inflated charitable tax deductions, and avoid federal income taxes on investment gains.  This article by Partner Hale Sheppard examines congressional incentives for making charitable donations, early warnings about potential abuse using charitable LLCs, major IRS guidance identifying theories for challenging taxpayers, and pending Tax Court cases involving charitable LLCs.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Services

Key contacts

halesheppard@eversheds-sutherland

Hale E. Sheppard

Partner

Atlanta, United States

Latest Insights

  • guides and reports
  • legal updates
  • legal updates
  • legal updates

Latest News

  • firm news
  • client news
  • client news
  • firm news

Latest Events

179087012_m

guides and reports

September 10, 2026

Coding in Action

legal updates

September 10, 2026

131648317_m

legal updates

September 10, 2026

AdobeStock_417045288-web

legal updates

September 09, 2026

© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website.