Ezel / IRS Rulings / 201207006

CCA 201207006: Chief Counsel advised that a Form 1099-MISC for a minor beneficiary should go to the minor

Number
201207006
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Information to Beneficiaries of Estates and Trusts
Topics
Procedure, penalties, and administration
Code sections
§ 6034A
Ruling dated
January 27, 2012
Publicly released
February 17, 2012
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2012, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2012
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advised that, under IRC § 6034A, a trust fiduciary must furnish a beneficiary with information about a distribution during the taxable year. Because the beneficiary in this situation was a minor, the advice concluded that Form 1099-MISC should be issued to the minor rather than to the parents. The conclusion addressed the reporting question presented in the request for assistance.

Ruling snapshot

  • Question: To whom should Form 1099-MISC be issued when a trust's beneficiary is a minor?
  • Outcome: advice
  • Key authorities: IRC § 6034A; Form 1099-MISC

Full text (IRS public release)

ID: CCA_2012012708494949 Number: 201207006
Release Date: 2/17/2012
Office: -------------
UILC: 6034A.00-00

From: --------------------------
Sent: Friday, January 27, 2012 8:50:00 AM
To: ------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------------------------
Subject: Question regarding information reporting

Hi,
This responds to your request for assistance dated 1/11/12 regarding Rev. Proc. 2011-56 and information reporting. Under section 6034A, the fiduciary of a trust must furnish to a beneficiary information concerning a distribution during the taxable year. In this instance, the minor is the beneficiary. Therefore, we conclude that the Form 1099-MISC should go to the minor, not the parents. Please contact me if you have any questions.

Thank you,
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