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 1207001: IRS approved proposed administrative changes to an irrevocable family trust
The IRS considered proposed changes to an irrevocable trust created before September 25, 1985, for the benefit of a child and the child's descendants. The changes would move the trust's…
PLR 1206005: Lump-sum divorce settlement receives favorable tax treatment
The IRS ruled on the income, gift, and estate tax treatment of a lump-sum payment from one former spouse to the other under a proposed modification of their divorce settlement. The payment was…
PLR 1205001: IRS approves dividing an irrevocable trust into separate trusts without current tax consequences
The IRS approved a proposed division of an irrevocable trust into two separate trusts, one holding partnership interests in real estate and the other holding marketable securities. The IRS ruled…
PLR 1151003: IRS grants time for an alternate valuation election
The IRS granted an estate an extension through the date a supplemental Form 706 was filed to make an alternate valuation election under IRC § 2032. The executor had timely filed the original return…
PLR 1148001: Unitrust conversion preserved QTIP and GST tax treatment
A surviving spouse and the other trust beneficiaries proposed converting a marital trust into a total return unitrust under state law. The trust was subject to a QTIP election, and a separate…
PLR 1147010: IRS approves reformation of a GST-exempt trust
A family sought to reform an irrevocable trust created before September 25, 1985, after discovering that a scrivener had omitted provisions allowing distributions to the settlor's children during…
PLR 1147005: IRS approves trust reformation for estate and gift tax purposes
A surviving spouse sought IRS rulings after a court modified a trust to correct a drafting error that had given the spouse a right to withdraw trust principal. The IRS concluded that, as modified,…
PLR 1144011: IRS grants more time for an estate's alternate valuation election
An estate asked for more time to make the alternate valuation election under § 2032 after its attorney failed to advise the executrix about the election. The IRS found that the estate met the…
PLR 1143002: IRS approves a trust beneficiary's proposed power of apportionment for estate and GST tax purposes
A trust beneficiary asked whether exercising a limited power to apportion trust assets among family members would cause those assets to be included in his gross estate. He also asked whether the…
PLR 1140001: QDOT trustee granted more time to report beneficiary citizenship
A qualified domestic trust trustee asked for more time to notify the IRS and certify that the surviving spouse beneficiary had become a United States citizen. The notice was missed because the law…
PLR 1136017: Trust distributions under testamentary powers of appointment retain GST-tax exemption
The taxpayer asked whether exercising testamentary powers of appointment over three trusts would cause the appointed property to be included in the beneficiary's gross estate. The IRS ruled that it…
PLR 1134017: Transfer of trust assets preserves GST status and avoids gift tax and gain
A taxpayer asked whether a special trustee could move assets from one family trust into a new trust for the same family beneficiary and descendants. The IRS ruled that the receiving trust would keep…
PLR 1132017: Trust modification prevents estate inclusion and does not create a gift
The IRS ruled on a court-approved modification of a revocable trust created by a married couple. The modification corrected a drafting error that directed the surviving spouse's debts, expenses, and…
PLR 1131014: IRS approved dividing an irrevocable trust into separate beneficiary subtrusts
A trustee proposed dividing an irrevocable trust created before September 25, 1985 into separate subtrusts, one for each of the grantor's three children and their descendants. The IRS concluded that…
PLR 1131011: IRS disregarded an unnecessary QTIP election for a marital trust
An estate elected to treat a marital trust as qualified terminable interest property, or QTIP, on its federal estate tax return. The estate represented that the election was unnecessary because the…
PLR 1129020: LLC transfer and crop-based lease preserve farmland valuation treatment
A qualified heir received an interest in farmland that had been valued under the special estate-tax rules of IRC § 2032A. The IRS ruled that transferring the interest to a wholly owned LLC would not…
PLR 1129019: Trust-to-LLC transfer and farm lease preserve section 2032A treatment
A trust held an interest in farmland that had been valued under the special estate-tax rules of IRC § 2032A for the benefit of qualified heirs. The IRS ruled that transferring the trust's farmland…
PLR 1129018: Trust-to-LLC transfer and farm lease preserve section 2032A treatment
A trust held an interest in farmland that had been valued under the special estate-tax rules of IRC § 2032A for the benefit of a qualified heir. The IRS ruled that transferring the trust's farmland…
PLR 1129016: Trust-to-LLC transfer and farm lease preserve section 2032A treatment
A trust held an interest in farmland that had been valued under the special estate-tax rules of IRC § 2032A for the benefit of qualified heirs. The IRS ruled that transferring the trust's farmland…
PLR 1129015: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, had not been divided as originally planned and was being administered for two beneficiaries. The trustees and beneficiaries proposed a nonjudicial…
PLR 1129014: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, was held for a beneficiary and later generations. The trustees and beneficiaries proposed a nonjudicial agreement to clarify investment authority,…
PLR 1129013: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, had not been divided as originally planned and was being administered for two beneficiaries. The trustees and beneficiaries proposed a nonjudicial…
PLR 1128015: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128014: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128013: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128012: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128011: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
TAM 1126030: “It is my desire” created mandatory specific bequests
The IRS addressed whether wording in a decedent's will created specific bequests to the decedent's children or merely expressed a nonbinding wish. The will said “it is my desire” that certain…
PLR 1125009: Qualified disclaimer allowed for remaining retirement interests, but not received distributions
The IRS considered whether a surviving spouse's estate could disclaim retirement-account interests inherited after the spouse's death. The spouse had received required minimum distributions that…
PLR 1125007: Trust reformation qualified for a charitable remainder deduction
The IRS ruled that a court-approved reformation of a revocable trust qualified under IRC § 2055(e)(3). The original trust provided a charitable remainder but did not use the annuity structure…
PLR 1122009: IRS grants an estate more time to elect alternate valuation
An estate timely filed its federal estate tax return, but its executor's first tax professional did not make the alternate valuation election under IRC § 2032. A second tax professional later…
PLR 1119004: IRS approved the division of a QTIP trust and the renunciation of one resulting interest
A decedent's estate had elected QTIP treatment for a marital trust benefiting the surviving spouse, with the remainder passing to two family trusts. The trustees planned to divide the marital trust…
PLR 1119003: IRS approved a fair-market-value exchange involving a marital trust
A marital trust and family beneficiaries planned a court-approved fair-market-value exchange to end shared ownership of certain entities and real property. The marital trust would buy some…
PLR 1118013: IRS grants extra time for a protective alternate valuation election
The IRS considered an estate that filed its federal estate tax return without a protective alternate valuation election under section 2032. The estate later filed a supplemental return making the…
PLR 1118007: IRS approves a trust severance and disclaimer plan involving QTIP property
The IRS considered a surviving spouse's proposed disclaimer of an interest in part of a QTIP marital trust after a state-court severance. The spouse planned to disclaim the interest in one new…
PLR 1117005: QTIP trust and charitable remainder unitrust provisions
The IRS considered proposed amendments to a revocable trust that would create a QTIP trust for the taxpayer's spouse and a charitable remainder unitrust. It ruled that the QTIP trust could qualify…
PLR 1116006: IRS excluded a former spouse’s trust from the decedent’s estate
The IRS considered an irrevocable trust established by a former spouse under a divorce judgment for the decedent’s lifetime benefit. The trust gave the decedent income and limited access to…
PLR 1116004: IRS granted time for reverse QTIP and GST elections
The IRS considered an estate that had reported a marital trust as QTIP property but had not separately identified its GST-exempt and GST-nonexempt portions, made a reverse QTIP election, or…
IRS approves a trust reformation into charitable lead and remainder trusts
The IRS ruled that a proposed judicial reformation of a testamentary trust would qualify under section 2055(e)(3). The reformation would create a charitable lead annuity trust that pays charities…
PLR 1112001: unnecessary QTIP election treated as null and void
The IRS treated a QTIP election for a family trust as null and void because the election was not needed to reduce the decedent's federal estate tax liability to zero. The executor had listed the…
PLR 1109014: The IRS granted more time to make an alternate valuation election
An estate asked for more time to make the alternate valuation election under IRC § 2032. The IRS had previously issued a ruling to the estate, then reconsidered the matter and concluded that 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 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 1103004: Estate receives more time to make a QDOT election
An estate of a noncitizen decedent left property in trust for a surviving noncitizen spouse and claimed the estate tax marital deduction. The estate's accountant failed to make the required…
PLR 1103003: Estate receives more time to make the alternate valuation election
An estate's executor filed the estate tax return without making the alternate valuation election because the accountant who began preparing the return died before it was completed. The executor…
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…
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.