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I don't know where you obtained your "understanding" of what a subsidiary LLC can do,but it does not sound right. It should be checked out carefully with verified authorities (which I am not, although I have served as legal counsel on several foundation boards). This information deals with subsidiary LLCs, but not specifically with fundraising activities in their own name. http://www.taxexemptsolutions.com/irs-takes-a-hard-line-on-private-benefit-and-private-inurement-rules/ ALSO SEE: http://www.taxexemptsolutions.com/why-and-how-should-a-nonprofit-create-a-subsidiary/ (This is not a recommendation or endorsement of that particular writer). I suggest obtaining a written legal opinion from an established tax authority on that subject and perhaps from the IRS itself before acting on it.
I did, and thanks for sending the update article. Unfortunately, I still can't tell you if there is a special form of notice to file with the IRS.