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 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…
CCA 1052007: The automatic extension rule may apply to missed estate tax elections
Chief Counsel Advice considered the extension rules for elections under IRC §§ 2032(d) and 2056A(d). It states that Treas. Reg. § 301.9100-2(b) applies when the taxpayer timely filed Form 706,…
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…
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.