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.
18,373 determinations and counting
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Newest release August 21, 2026
902 determinations
Gst Tax
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PLR
PLR
PLR 1049012: Estate receives more time to allocate GST exemption
This ruling addresses an irrevocable trust funded by a lifetime transfer for which the donor's available generation-skipping transfer tax exemption was not allocated on Form 709. The IRS found that…
PLR 1049008: Trust modifications will preserve a zero GST inclusion ratio
This ruling addresses a court-approved modification of an irrevocable trust with a zero generation-skipping transfer tax inclusion ratio. The modification would split the trust into three family…
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.
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