At the Council on Foundation Conference, former director of the Exempt Organizations division of the IRS Marcus Owens discussed the concept of a new form of legal entity that might be an appropriate vehicle (1) for social enterprises, and (2) to receive program-related investments - the low-profit limited liability company or L3C. The L3C would be a type of limited liability company created under state law to generate modest profit while carrying on a business that has a charitable purpose.
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