Ezel / IRS Rulings / 201348013

CCA 201348013: Counsel agrees with the technical position on GRAT asset distributions

Number
201348013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Rules Determining Income or Loss; Other Definitions and Rules
Topics
Accounting methods and periods
Code sections
§ 469
Publicly released
November 29, 2013
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 2013, 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 2013
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 confirmed its position on applying IRC § 469(j)(6) to distributions of assets from a grantor retained annuity trust (GRAT). Counsel agreed with the position taken by the Technical Advisors. The message says the taxpayers' interpretation of the statute appeared reasonable, but that the Technical Advisors' position provided the best reading of the statute.

Ruling snapshot

  • Question: How does IRC § 469(j)(6) apply to distributions of assets from a GRAT?
  • Outcome: advice given
  • Key authorities: IRC § 469(j)(6)

Full text (IRS public release)

ID:        CCA_2013091217263252
Office: -----------------
UILC:      469.05-00, 469.10-00
Number: 201348013
Release Date: 11/29/2013
From: ----------------------
Sent: Thursday, September 12, 2013 5:26:36 PM
To: ------------------------
Cc: ------------------------------------------------------
Subject: Confirmation


-----------------
   This is to confirm our telephone conversation of earlier today. In that conversation,
we indicated that we agree with the position taken by the Technical Advisors regarding
the application of § 469(j)(6) to the distribution of assets from a GRAT. Even though we
agree that the taxpayers' interpretation of the statutory provision appears reasonable,
we believe that the Technical Advisors’ position provides the best reading of the statute.
 Feel free to call ------------------------------or me if you would like to discuss further.
Thanks.


-----------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------------------
------------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace