Technical Advice Memoranda

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The Service has ruled in technical advice that an organization is properly classified as a supporting organization under section 509(a)(3). At issue was whether the organization was controlled directly or indirectly by one or more disqualified persons. The Service...
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The Service has ruled in technical advice that loans from a corporation that is a disqualified person with respect to a private foundation to another business entity, a portion of which is also owned by the private foundation, is not an indirect act of self-dealing...
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In technical advice, the Service has ruled that an individual's bequest to a sister who belongs to a religious order and took a vow of poverty does not qualify for an estate tax charitable deduction.
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The IRS has ruled in technical advice that although an organization is no longer a church, it will retain its tax-exempt status and be subject it to intermediate sanctions for automatic excess benefit transactions and political intervention.
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The Service has ruled in technical advice that no gift tax charitable deduction is allowed for transfers to a trust that is subject to four charities' withdrawal powers. Further ruled, each transfer is includable in the computation of adjusted taxable gifts to the...
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In this Technical Advice Memorandum, the IRS held that a broadcasting company is not entitled to an income tax charitable deduction for contributing its zero basis film library to a public charity, in part because the film library is not a capital asset.
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IRS is barred by the 3-year statute of limitations from taking action against a private foundation and disqualified person for a self-dealing transaction.
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In Technical Advice Memorandum 200021056, the Service concluded that a tax-exempt organization's operation of a gift shop and tea room were unrelated to its exempt purpose and held that the resulting income constitutes unrelated business taxable income and further held...
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In TAM 200003005, the Service advised, in part, that a printing company did not meet the requirements for an increased charitable deduction under Section 170(e)(3) of the Code for donated inventory because the company could not demonstrate that the donated materials...
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In TAM 199941004, the IRS concluded that the decedent's estate is not eligible for a charitable deduction for the present value of the remainder interest of a charitable remainder trust. The IRS held that the trust is not a "reformable interest" because (i) the...
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Ever since last April when Treasury issued proposed regulations calling for commentary regarding the use of various investment strategies that enable the trustee of a NIMCRUT to control the receipt of distributable income by the trust, and concurrently announced in...

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In TAM 199908039, the Service holds that an S Corporation's shareholders can claim a deduction for charitable contributions made by the corporation to a related foundation only in the year in which the contributions are actually paid.
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Based on the legislative history to Code Section 2055(e)(3), the IRS has ruled in technical advice that a retroactive amendment of an inter vivos trust to qualify as a charitable remainder unitrust is permissible under the law.
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In TAM 9842004, the IRS rules that a bequest to a trust to be held in a foreign country for cultural endeavors and assistance to the needy qualifies for the charitable estate tax deduction under Code Section 2055(a)(3).
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In technical advice, the IRS has ruled that no charitable income tax deduction was allowed for a gift of property subject to an option exercisable by the donor until the year in which the option expired. When the option expired, a charitable income tax deduction was...
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The IRS has issued a Technical Advice Memorandum in which it approved an arranagement whereby the trustee of a charitable remainder unitrust invested trust assets in two tax deferred annuity contracts for the purpose of controlling the timing and amount of trust income...
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Define: Technical Advice Memoranda

A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director in response to technical or procedural questions that develop during a proceeding. A request for a TAM generally stems from an examination of a taxpayer’s return, a consideration of a taxpayer’s claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals. TAMs are issued only on closed transactions and provide the interpretation of proper application of tax laws, tax treaties, regulations, revenue rulings or other precedents. The advice rendered represents a final determination of the position of the IRS, but only with respect to the specific issue in the specific case in which the advice is issued. Like PLRs, TAMs are not precedential for other taxpayers and are generally made public after all information has been removed that could identify the taxpayer whose circumstances triggered a specific memorandum.