Letter Rulings

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When is an irrevocable trust revocable? The recently adopted Uniform Trust Code (UTC) was supposed to make all of this more clear, but a recent case in New Mexico has muddied the waters for all practitioners.

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15 May 2014 | Letter Rulings | National Publication | News story

In a recent ruling, the tax court allowed the transfer of assets from a charitable trust to a private foundation that were both governed by substantially the same family. The courts still held, among other things, that there was no act of self-dealing, there were no...

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A substantial and material change in the sources of support of a public charity described in IRC Sections 170(b)(1)(A)(vi) or 509(a)(2), which are dependent on a sufficient amount of public support for their public charity status, may potentially cause an...

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In recently issued Ltr. Rul. 201323007, the taxpayer created a charitable lead annuity trust ("CLAT"), where the beneficiary of the income interest was a private foundation. The foundation was established by the taxpayer and his spouse and the taxpayer, his spouse,...

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IRS section 642(c)(1) provides that estates and certain trusts can elect to deduct charitable contributions made in the current year on their prior year's income tax return. In this case, the IRS has ruled privately that a trust that had intended but failed to make...

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30 Oct 2013 | Letter Rulings | National Publication | News story

The Service has ruled privately that a court ordered reformation of a net income with make-up provision charitable remainder unitrust to bring the trust into compliance with current law will not cause it to fail to qualify as charitable remainder unitrust under I.R....

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19 Aug 2013 | Letter Rulings | National Publication | News story

The IRS has approved the reformation of a testamentary charitable remainder unitrust (CRUT) that was funded via formula in the trustor's revocable living trust in an amount that exceeded the unified credit exclusion amount provided under law at the time of the...

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19 Aug 2013 | Letter Rulings | National Publication | News story | 1 comments

The IRS has ruled privately that a private foundation's ownership interest in an LLC that is taxed as a partnership and that operates solely as a hedge fund will not generate unrelated business taxable income to the foundation, will not subject the foundation to the...

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19 Aug 2013 | Letter Rulings | National Publication | News story

In most cases the PGDC does not comment on rulings involving denials of tax-exempt status unless they involve high-profile issues or concepts of general application. In this case, a corporation organized as a cooperative that facilitates and organizes transactions...

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14 Aug 2013 | Letter Rulings | National Publication | News story

The IRS has approved a court ordered reformation of a net income with make-up provision charitable remainder unitrust to eliminate a requirement that would require the trustee to treat any deficiency account balance as a liability when valuing the trust for purposes...

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29 Jul 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that an assignment by a trustee of two IRAs to two charitable organizations from the residue of an estate would be income in respect of a decedent only to the charities in the amounts received by each. Of course, this is the ideal result...

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24 Jul 2013 | Letter Rulings | National Publication | News story | 1 comments

The IRS has ruled privately that a private foundation's investment in Class A membership interests in an LLC that operates a hedge fund and is treated as a partnership for federal tax purposes will not generate unrelated business taxable income to the foundation,...

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14 Jul 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation may have an additional five years to dispose of its excess business holdings. The foundation stated that despite making a diligent effort during the initial five-year period, disposition was not possible (except...

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28 Jun 2013 | Letter Rulings | National Publication | News story

The IRS has approved the early termination of a couple's net income with makeup charitable remainder unitrust (NIMCRUT) and distribution of trust assets to its income and remainder beneficiaries, each according to the present value of their interests on the date of...

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12 Jun 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that an individual's transfer to a charitable lead annuity trust that makes payments to a private foundation created by him is a completed and deductible gift for Federal gift tax purposes and that no portion of trust's property will be...

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12 Jun 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation's receipt of stock in a corporation that houses original artworks and their copyrights of a prominent deceased artist and the creation of a Collection Agreement whereby the foundation will receive compensation...

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11 Jun 2013 | Letter Rulings | National Publication | News story

The IRS has revoked the exempt status of a private foundation based on its failure to establish operations are exclusively for exempt purposes, impermissible private benefit and earnings inuring to insiders, and failure by the foundation to maintain sufficient...

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30 May 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a married couple's assignment of their income interests in two charitable remainder unitrusts, in which they are named joint and survivor income recipients,...

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30 May 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation that makes scholarship grants under an employer-related program to the children of employees will not be a taxable expenditure to the foundation or taxable income to the recipients based on that foundation's...

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Define: Letter Rulings

A private letter ruling (PLR or Ltr. Rul.) is a written statement issued by the IRS to a taxpayer that interprets and applies tax laws to the taxpayer’s specific set of facts. It is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer’s return is filed. It is issued in response to a written request submitted by a taxpayer and is binding on the IRS if the taxpayer fully and accurately described the proposed transaction in the request and carries out the transaction as described. A private letter ruling may not be relied on as precedent by other taxpayers or IRS personnel. Private letter rulings are generally made public after all information has been redacted that could identify the taxpayer to whom it was issued.

Recent activity

Private Foundation Permitted to Own Hedge Fund

IRS Approves Private Foundation's Investment in LLC

Issuance of Units from Organization's Endowment Fund to CRT Does Not Cause UBTI

Issuance of Units by University to CRTs Does Not Produce Unrelated Business Income

Grants to Foreign Charities are Qualifying Distributions

Charitable Deduction for Artwork

Reinsurance of CGA Not Commercial Insurance or UBI