Ezel / IRS Rulings / 1207006
Chief Counsel Advice 1207006 Released February 17, 2012 Advice

CCA 1207006: Chief Counsel advised that a Form 1099-MISC for a minor beneficiary should go to the minor

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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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