Letter Rulings

Bulk operations
Rated
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...

5
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...

0
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...

0
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...

0
30 May 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a transfer of assets from one private foundation to another does jeopardize either foundation's exempt status, does not give rise termination taxes or net...

5
30 May 2013 | Letter Rulings | National Publication | News story

The Service has ruled privately that a proposed settlement agreement, arising from a dispute between the heirs of a decedent and a private foundation, in which the heirs will purchase limited...

0
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...

0

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...

0

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...

3
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...

0
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...

0
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...

0
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...

0
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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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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