Document Type


Publication Date



Monica Gianni discusses how the IRS’s analysis of a private operating foundation using an LLC in LTR 9834033 indicates the IRS’s approach to LLCs with exempt organization members.


This article is reprinted with the publisher’s permission from the Journal of Passthrough Entities, a bi-monthly journal published by Wolters Kluwer. Copying or distribution without the publisher’s permission is prohibited. To subscribe to the Journal of Passthrough Entities or other Wolters Kluwer Journals please call 800-449-8114 or visit All views expressed in the articles and columns are those of the author and not necessarily those of Wolters Kluwer or any other person. © CCH Incorporated. All Rights Reserved.

Included in

Tax Law Commons