IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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PLR 1110005: IRS grants late GST exemption allocation relief for fifteen trusts
The IRS granted an estate 120 days to allocate the decedent's generation-skipping transfer tax exemption to transfers made to fifteen irrevocable trusts. The decedent's accounting firm had failed to…
PLR 1110004: IRS grants spouses additional time to allocate GST exemptions to five trust transfers
The IRS granted Donor and Spouse 120 days to allocate their respective generation-skipping transfer tax exemptions to transfers made to five irrevocable trusts. Their accountant had reported the…
PLR 1109016: The IRS granted more time for a reverse QTIP election and GST exemption allocation
An estate asked for more time to make a reverse qualified terminable interest property (QTIP) election and allocate the decedent's generation-skipping transfer tax exemption to two trusts. The…
PLR 1109010: The IRS granted more time to allocate GST exemption to four trusts
An individual asked for more time to allocate generation-skipping transfer (GST) tax exemption to transfers made to four trusts for the benefit of children and their descendants. The individual had…
PLR 1109009: The IRS granted an estate more time to allocate GST exemption to four trusts
The executor of an estate asked for more time to allocate the decedent's generation-skipping transfer (GST) tax exemption to transfers made to four trusts for the benefit of children and their…
PLR 1109005: The IRS granted more time to allocate GST exemptions to trust transfers
Grantor and Spouse asked for more time to allocate their generation-skipping transfer tax exemptions to transfers made to an irrevocable trust. Their accountant and tax preparer failed to make the…
PLR 1109004: The IRS approved a trust division and related tax treatment
The trustee of an irrevocable trust asked to divide it into two successor trusts, one for each family line, and to modify several distribution and administrative provisions. The IRS addressed the…
PLR 1108010: Family receives more time to allocate GST tax exemptions
A donor and spouse failed to allocate their generation-skipping transfer tax exemptions to transfers made to a trust. The failure occurred when their accountant did not prepare the required…
PLR 1108005: Spouses receive more time to allocate GST exemptions
A husband and wife created and funded a trust but their law firm failed to report the transfers on their gift tax returns and did not allocate their generation-skipping transfer tax exemptions. The…
PLR 1108002: Spouses receive more time to allocate GST exemptions to a trust
A husband and wife transferred interests in a limited partnership to a trust but their tax adviser failed to allocate their generation-skipping transfer tax exemptions on their gift tax returns. The…
PLR 1104022: IRS grants more time to allocate generation-skipping transfer tax exemption
A donor asked for more time to allocate available generation-skipping transfer tax exemption to five irrevocable trusts created for the donor's children and their descendants. The donor had filed a…
PLR 1104012: IRS grants more time to opt out of automatic GST exemption allocation
A donor asked for more time to elect out of the automatic allocation of generation-skipping transfer tax exemption to transfers made to an irrevocable trust. The donor relied on law and accounting…
PLR 1104003: IRS approves a trust conversion and new trusts without loss of GST tax exemption
The trustee of a pre-September 25, 1985 trust asked whether converting the trust's income interest to a unitrust interest and creating two descendant trusts would preserve the trust's exemption from…
PLR 1104001: IRS approves a settlement dividing a family trust without added transfer tax
A family asked how a proposed court-approved settlement of long-running disputes over two trusts would affect income, gift, estate, and generation-skipping transfer taxes. The settlement divided one…
PLR 1103039: Spouses receive extra time to allocate GST exemptions to family trusts
A married couple asked for more time to allocate their generation-skipping transfer tax exemptions to transfers made to three trusts for their children and grandchildren. Their accountant had failed…
PLR 1103024: Taxpayers may make a late allocation of generation-skipping transfer tax exemptions
A married couple transferred cash to an irrevocable trust for their daughter and her descendants but did not timely allocate their generation-skipping transfer tax exemptions to the transfer. Their…
PLR 1103023: Husband and wife may make late allocations of GST exemptions
A married couple transferred cash to an irrevocable trust for their daughter and her descendants but did not timely allocate their generation-skipping transfer tax exemptions to the transfer. Their…
PLR 1103016: Taxpayers may make late formula allocations of GST exemption to trust transfers
A donor and spouse transferred stock and a partnership interest to an irrevocable trust, but their tax preparer did not allocate their available generation-skipping transfer tax exemptions to the…
PLR 1102053: IRS grants more time to allocate a deceased spouse’s GST exemption
A grantor and spouse made gifts to an irrevocable trust and elected to treat the gifts as made one-half by each spouse. Their accounting firm prepared the gift tax returns but failed to allocate the…
PLR 1102052: Trust settlement avoids transfer taxes and gain recognition
A family sought rulings on the federal tax effects of a mediated settlement involving two trusts created under a decedent’s will. The settlement resolved long-running disputes involving the rule…
PLR 1102051: IRS approves a settlement of disputed trust interests without additional tax recognition
A family settled a long-running dispute over how two trusts should distribute income and principal to descendants. The settlement used a negotiated fractional split between competing per capita and…
PLR 1102024: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102023: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102022: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102021: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102020: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102019: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102018: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102017: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102016: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102015: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102014: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102013: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102012: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102011: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102010: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102009: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102008: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102007: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102006: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102005: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102004: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1101009: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101008: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101007: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101006: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101005: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101004: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101003: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101002: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101001: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1052002: Court-approved trust settlement does not trigger the described tax consequences
A trust's beneficiaries were litigating how trust income and principal should be distributed under a will, a later agreement, and state law. They proposed a court-approved settlement that divided…
PLR 1051023: Trust settlement will not trigger GST, gift, estate, or income tax
The IRS considered a proposed settlement of litigation over two trusts created under a deceased person's will. The dispute concerned the rule against perpetuities, how trust principal and income…
PLR 1051004: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051003: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051002: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1050008: IRS approved consolidating three trusts without triggering new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050006: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050005: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1049016: Trust reformation will preserve GST tax exemption
This ruling addresses a proposed court-approved reformation of a trust created under a decedent's will. The reformation would correct a scrivener's error that left the trust's distribution terms…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.