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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Estate receives 120-day extension for portability election
An estate below the mandatory estate-tax filing threshold missed the deadline to file Form 706 and elect portability of the deceased spouse's unused exclusion amount. Because the estate was not…
Estate receives 120 days to make omitted QTIP election
A decedent's revocable trust created a marital trust that paid all net income to the surviving spouse for life. The estate timely filed Form 706, but its attorney mistakenly omitted the trust from…
Estate received 120 days to make a portability election
An estate below the estate-tax filing threshold missed the deadline to file Form 706 and elect transfer of the deceased spouse's unused exclusion amount to the surviving spouse. Because the estate…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Estate received more time to elect portability
An estate missed the deadline to file Form 706 and elect portability of the deceased spouse’s unused estate and gift tax exclusion for the surviving spouse. The estate represented that the…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Trust settlement avoided transfer taxes and recognized gain
A family settled litigation over the administration and interpretation of a trust created by a person who died before September 25, 1985. The court-approved agreement divided the trust into one…
Court settlement dividing family trust avoids transfer taxes and gain
A pre-1985 family trust produced disputes over trustee investment adjustments, whether the trust could be divided, and how the phrase "by right of representation" governed future distributions.…
Trust settlement and division do not trigger transfer taxes or gain
An irrevocable testamentary trust created before September 25, 1985, paid income to three family branches and was scheduled to end after the last survivor of two beneficiaries died. A dispute arose…
Court settlement dividing family trust avoids transfer taxes and gain
A pre-1985 family trust produced disputes over trustee investment adjustments, whether the trust could be divided, and how the phrase "by right of representation" governed future distributions.…
Court settlement dividing family trust avoids transfer taxes and gain
A pre-1985 family trust produced disputes over trustee investment adjustments, whether the trust could be divided, and how the phrase "by right of representation" governed future distributions.…
Court settlement dividing family trust avoids transfer taxes and gain
A pre-1985 family trust produced disputes over trustee investment adjustments, whether the trust could be divided, and how the phrase "by right of representation" governed future distributions.…
Court settlement dividing family trust avoids transfer taxes and gain
A pre-1985 family trust produced disputes over trustee investment adjustments, whether the trust could be divided, and how the phrase "by right of representation" governed future distributions.…
QTIP severance confines gift and estate consequences to the disclaimed trust
An estate had elected qualified terminable interest property treatment for a marital trust benefiting the surviving spouse. The trustee proposed dividing the GST nonexempt portion into two trusts…
Trust division preserved tax treatment and asset basis
A trust for a daughter and her descendants proposed dividing its assets equally between two successor trusts, one for each family line. The daughter would remain a beneficiary of both trusts, and…
QDOT trustee receives more time to report spouse's citizenship
A qualified domestic trust was established for a surviving spouse who was not a U.S. citizen when the decedent died. The spouse later became a citizen after continuously residing in the United…
Trust division and court modifications preserve grandfathered GST status
A will created a trust before September 25, 1985, but left ambiguity about when the trust ended and how its assets passed after the original beneficiary's death. A state court construed the trust to…
Trust division and court modifications preserve grandfathered GST status
A will created a trust before September 25, 1985, but left ambiguity about when the trust ended and how its assets passed after the named family members died. A state court construed the trust to…
Four-way trust division preserves tax status without gain, gift, or estate inclusion
A trust created before September 25, 1985 benefited one child, that child's spouse, four grandchildren, and their families. A state court approved dividing it equally into four trusts, one for each…
Court-approved trust division triggers no transfer tax or gain
A family settled litigation over the administration and meaning of a trust created before September 25, 1985. The court-approved agreement terminates the original trust, divides its assets into two…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
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.