Letter Rulings

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Richard Fox analyzes and clarifies a recent PLR involving a CRT. There are interesting opportunities to explore subsequent to this ruling.
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The Service has ruled privately that the transfer of a portion of a charitable remainder unitrust's assets into a new unitrust, followed by the assignment of the trustor's income interest in the new trust to the charitable remainderman, and the distribution of the new...
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The IRS has ruled privately that a charitable remainder trust, that through a drafting error permitted naming only public charities as remaindermen, could be reformed to enable the trustor to designate the remainder interest to one or more private nonoperating...
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The IRS has ruled privately that an estate tax charitable deduction will be available to the estate of a taxpayer that names a private foundation as beneficiary of IRA and qualified retirement plan proceeds. The foundation will have income in a respect of a decedent;...
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The estate plan of a married couple provides that on their deaths a substantial portion of their estates, which include units in a family limited partnership, will be transferred to the family's private foundation. In order to avoid the potential problems associated...
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11 May 1998 | Letter Rulings | National Publication | News story
The Internal Revenue Service has ruled privately in PLR 9819031 that a corporate recapitalization did not constitute a taxable dividend distribution and the "new" stock could be used to fund a qualified charitable lead annuity trust.
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26 May 1998 | Letter Rulings | National Publication | News story
The Service has ruled privately that a beneficiary of a living trust who holds a limited power to appoint trust principal to individuals or charity may appoint the principal to a charitable remainder unitrust. The unitrust amount will be paid to the living trust for a...
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26 May 1998 | Letter Rulings | National Publication | News story
The IRS has ruled privately that a trustor's gift to a charitable lead unitrust trust will be complete for gift tax purposes and not includible in the trustor's estate. In addition, the CLT will be entitled to deductions for amounts paid to charity.
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26 May 1998 | Letter Rulings | National Publication | News story
The IRS has ruled privately that a testamentary trust can be reformed into a NIMCRUT with a 7.5 percent unitrust amount payable to the named beneficiary for her lifetime or until she remarries.
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The IRS has ruled privately that a court modification to cure a drafting error in which the donor's legal counsel inadvertently included an "income only" provision in a charitable remainder unitrust will not disqualify the trust.
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In a ruling similar to Ltr. Rul. 9821030 (reported by the PGDC on May 26, 1998), the Service has ruled in Ltr. Rul. 9822018 that a donor's gift to a charitable lead unitrust will be completed for gift tax purposes and not includible in the donor's estate. In addition,...
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The IRS has ruled privately that a charitable lead annuity trust will be entitled to an income tax deduction for amounts paid to charity and will not be a grantor trust for income tax purposes.
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The Service has ruled privately that a donor created a valid non-grantor CLAT. The assets of the CLAT would not be includable in the gross estate of the donor notwithstanding the fact that a separate committee of the donor's private foundation selected the charities to...
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The Service has ruled privately that a decedent will obtain a charitable deduction for the present value of the remainder interest in a Charitable Remainder Trust that will be created pursuant to a reformation of a family trust. The beneficiary of the family trust...
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23 Jun 1998 | Letter Rulings | National Publication | News story
The IRS has ruled privately that stock, which is restricted under SEC Rule 144, and American Depository Reciepts (ADRs) may be "qualified appreciated stock" under Code Section 170(e)(5).
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23 Jun 1998 | Letter Rulings | National Publication | News story
The IRS has ruled privately that a taxable corporation's conversion to a tax-exempt, nonprofit title-holding corporation, which is to be accomplished prior to the effective date of the proposed regulations under Code Section 337, would not cause gain or loss to be...
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29 Jun 1998 | Letter Rulings | National Publication | News story
The IRS has ruled privately that the reformation of an inter vivos charitable remainder unitrust to allow the charitable remainder beneficiaries to include private foundations will not disqualify the trust under Code Section 664. The taxpayers presented evidence that...
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In private letter ruling 9827008, the IRS rules that an estate will be entitled to a charitable deduction for the present value of the remainder interest in a trust provided that the non-charitable beneficiaries of the trust validly disclaim their powers to invade...
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In private letter ruling 9827010, the IRS rules that an estate will be entitled to a charitable deduction for the present value of the remainder interest in a trust and for the present value of a guaranteed annuity in a trust provided that the non-charitable trust...
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The Service has ruled privately that two trusts qualify as valid charitable remainder unitrusts under Code Section 664(d)(2) despite the fact that all interests in the trusts are incomplete gifts for federal gift tax purposes.
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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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