Letter Rulings

Bulk operations
Rated
15 May 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation's scholarship grants to individuals who have been diagnosed (or members of their immediate family) with a specific medical condition and who meet other specific criteria are not prohibited taxable expenditures...

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The IRS has ruled privately that if certain section 1250 property (depreciable real property) is contributed to one or more tax-exempt organizations by a corporate donor, the charitable deduction attributable to the value of that contribution will not be reduced by...

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The IRS has ruled privately that expenditures by a private foundation in connection with awarding educational mentorship grants will not be taxable to the foundation.

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23 Apr 2013 | Letter Rulings | National Publication | News story

The Service has ruled privately that a settlement in connection with bona fide will contest will entitle an estate to a charitable deduction under section 2055(a) for amounts passing to charity pursuant to the settlement.

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16 Apr 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a ranch owned by a 501(c)(3) organization is being used and held by it for use directly in carrying out its charitable, educational and...

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

The IRS has revoked the tax exempt status of an organization that operated a "donor advised fund" for a single individual donor based on its determination that funds and...

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

The IRS has ruled privately that an organization that advocates the practice of polygamy in violation of state laws and state and federal public policy does not qualify as a religious organization and, therefore, is not exempt from Federal income tax...

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24 Jan 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation's ownership of nonvoting stock, the majority of which is owned by substantial contributors to the foundation, will be permitted holdings and will not be excess business holdings. Further ruled, family...

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10 Dec 2012 | Letter Rulings | National Publication | News story

The Service has ruled privately that a couple's proposed contribution of an undivided interest in their payments from a charitable remainder unitrust and irrevocable designation of the remainder interest to the same charity, followed by a partial termination of the...

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13 Sep 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that payments from the residuary estate of a decedent, in connection a proposed settlement agreement, to three charitable organizations will be deductible as a charitable transfer under § 2055. The settlement was proposed in...

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17 Aug 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation that owns stock in a company that is subject to the rule against excess business holdings may have an additional five years to dispose of the stock. The foundation stated that despite its best...

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The IRS has ruled privately that the division of a charitable lead unitrust into two trusts in order to facilitate the trustees' different charitable philosophies and divergent charitable goals will not result in a termination of private foundation status;...

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14 Jun 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation's procedures for granting of awards comply with the requirements of the Code and that awards granted in accordance with such procedures will not constitute "taxable expenditures" within the meaning...

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14 Jun 2012 | Letter Rulings | National Publication | News story

The Service has ruled privately that transfers, contributions or sharing of assets, personnel, facilities and services, including the execution of contracts for the sharing of assets and services between a supporting organization and it supported organizations shall...

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The Service has ruled privately that the conveyance of the perpetual conservation easement on property in exchange for mitigation credits is a sale or exchange of property under section 1001 for federal income tax purposes. 

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The IRS has ruled that a pooled income fund creator's reacquisition of real property it sold to a pooled income fund followed by the sale of the property to a newly created fund will not cause the funds to be disqualified or be a prohibited act of self-dealing...

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The Service has ruled privately that differences between the governing instrument of a pooled income fund created to raise capital to purchase and renovate buildings and the sample declaration of trust and instruments for pooled income funds provided...

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23 May 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a supporting organization that is treated as private foundation can have five additional years to dispose of its excess business holdings with respect to each of the increases in its holdings in a company's voting stock...

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14 May 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a family charitable trust does not meet the organizational test because it benefits named private individuals which is in direct contradiction to section 501(c)(3) of the Code. Further ruled, the organizing document fails to...

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30 Apr 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a state court's order to permit optional variable ascending annuity payments from a testamentary charitable lead annuity trust, commencing on the decedent's death and continuing for the 10-year annuity term, will satisfy...

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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.

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