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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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…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Retained trust powers keep the grantor's transfer incomplete
A grantor proposed an irrevocable trust with a committee that could direct distributions, while the grantor retained consent, support, and testamentary appointment powers. The IRS concluded that the…
Self-settled trust remains grantor-owned and gifts incomplete
A trustor proposed an irrevocable trust for herself and her descendants. An independent distribution adviser could direct distributions to the trustor, while distributions to descendants required…
Pooled income fund sale-leaseback receives favorable tax rulings
A tax-exempt organization created a pooled income fund that would buy a building and its land from the organization, then lease them back for 25 years. The IRS ruled that four identified differences…
IRA transfer from estate trust to charity does not accelerate income
A decedent named a trust as the primary beneficiary of an IRA, and the trust's remaining property was distributable to a charity after two cash bequests. The estate and trust planned to assign and…
ESOP may adopt a minimum formula for releasing charitable-trust stock
A charitable remainder trust transferred employer stock to an employee stock ownership plan after the income beneficiary's death. The shares were held in a suspense account subject to IRC § 664(g),…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
IRA-funded charitable bequests trigger IRD without trust deduction
A decedent's trust was the beneficiary of an IRA and owed fixed-dollar bequests to two charities that exceeded its non-IRA assets. A state court reformed the trust in an effort to treat IRA payments…
Pro rata trust divisions preserve GST status and tax attributes
Two irrevocable trusts created before September 25, 1985, held assets for four children and their descendants. The trustee proposed dividing each trust pro rata into four successor trusts so…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Trust could divide inherited IRA among 18 beneficiaries without immediate tax
A decedent named a trust as beneficiary of four IRAs, which were consolidated into one IRA after his death. After other specified distributions, the trust had 18 remaining individual beneficiaries…
Settlor's retained powers made trust funding an incomplete gift while committee distributions were not committee members' gifts
A settlor proposed an irrevocable trust whose distribution committee could make unanimous distributions, while the settlor retained consent, support, and testamentary appointment powers. The IRS…
Court reformation of charitable remainder trust avoided self-dealing
A charitable remainder trust was intended to pay a fixed percentage of its assets each year, but the drafting attorney used language that limited payments to trust income. The trustees had…
Consolidating identical unitrusts preserves surviving trust's status
Two charitable remainder unitrusts had substantially identical terms, trustees, income beneficiaries, payout percentages, and charitable remainder beneficiaries. Their trustees proposed transferring…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
IRS rules on trust ownership and gift-tax treatment of distributions
The IRS ruled on income-tax ownership and gift-tax consequences for an irrevocable trust controlled through a grantor and a distribution committee. It concluded that the grantor was not treated as…
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.