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 1349002: Trust division does not trigger additional transfer or income tax consequences
Trustees proposed dividing an old irrevocable trust into three separate trusts, one for each of a beneficiary's family lines, so the shares could be managed under different investment approaches.…
PLR 1349001: Grantor trust treatment controls a proposed asset transfer
The IRS considered two trusts, one revocable and one irrevocable, and a proposed transfer of a partnership interest from the first trust to an LLC for cash and a promissory note. The IRS ruled that…
PLR 1345034: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
PLR 1345033: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
Grantor trusts are disregarded for attribution and loss limitation analysis
Chief Counsel addressed the federal tax treatment of grantor trusts in a structure involving a limited liability company, related partnerships, and multiple trusts. The advice concluded that grantor…
PLR 1343002: trust granted time to make charitable contribution election
The IRS granted a trust 120 days to make an election under IRC section 642(c)(1) for a charitable contribution paid in a later tax year to be treated as paid in an earlier year. The trustee had…
PLR 1342001: IRS approves tax treatment of a court-approved trust division
A family asked the IRS about the tax consequences of a court-approved settlement dividing an old irrevocable trust into four separate trusts, with each child's trust divided again into Trust A and…
PLR 1340012: IRS approves a judicial reformation of a charitable remainder unitrust
The IRS concluded that a court-approved reformation of an irrevocable trust would not prevent the trust from qualifying as a charitable remainder unitrust. The trust had been intended to end at the…
PLR 1338028: IRS approves dividing an inherited IRA into three sub-IRAs
An estate proposed dividing an inherited individual retirement account into three sub-IRAs for the people who became entitled to the account under state intestacy law. The IRS ruled that the…
PLR 1333006: IRS approves reformation of a trust into a qualifying charitable remainder unitrust
An estate asked whether a court-approved reformation of a trust could qualify under IRC § 2055(e)(3). The proposed changes divided the trust, addressed payments for certain noncharitable expenses,…
PLR 1332012: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
PLR 1332011: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
PLR 1330011 approves transfers of inherited IRA rights to charities
The IRS rules that an estate's assignment of inherited IRA rights to two charitable beneficiaries will not be treated as a transfer under IRC § 691(a)(2). The estate and trust were authorized to…
PLR 1326011: Grantor treated as owner of trust income and corpus during the trust term
The IRS ruled that a grantor would be treated as the owner of a trust's income and corpus for federal income tax purposes during the trust term. The trust required its net income to be paid to the…
PLR 1325021: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325020: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325019: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325018: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1320009: IRS approves converting grandfathered trusts to unitrusts
The IRS considered whether two irrevocable trusts created before September 25, 1985 could be converted to unitrusts under a state statute. The proposed conversion would define trust income as a…
PLR 1310006: Trust powers do not make committee members the taxable owners or gift donors on the submitted facts
The IRS considered an irrevocable trust created for a grantor's descendants, with distributions controlled by a distribution committee and certain powers retained by the grantor. It concluded that…
PLR 1310005: Trust powers do not make committee members the taxable owners or gift donors on the submitted facts
The IRS considered an irrevocable trust created for a grantor's descendants, with distributions controlled by a distribution committee and certain powers retained by the grantor. It concluded that…
PLR 1310004: Trust powers do not make committee members the taxable owners or gift donors on the submitted facts
The IRS considered an irrevocable trust created for a grantor's descendants, with distributions controlled by a distribution committee and certain powers retained by the grantor. It concluded that…
PLR 1310003: Trust powers do not make committee members the taxable owners or gift donors on the submitted facts
The IRS considered an irrevocable trust created for a grantor's descendants, with distributions controlled by a distribution committee and certain powers retained by the grantor. It concluded that…
PLR 1310002: Trust powers do not make committee members the taxable owners or gift donors on the submitted facts
The IRS considered an irrevocable trust created for a grantor's descendants, with distributions controlled by a distribution committee and certain powers retained by the grantor. It concluded that…
PLR 1249002: IRS approves charitable transfers involving a remainder unitrust
The IRS ruled that a surviving donor could transfer an undivided portion of a charitable remainder unitrust payment and the related trust remainder to the charitable remainder beneficiary. The donor…
PLR 1245008: IRS grants extra time to make a trust distribution election
The IRS granted a trust 120 additional days to make a section 663(b) election. The trust had distributed an amount during the first 65 days of a tax year and intended the distribution to be treated…
PLR 1245007: IRS approves the division of an irrevocable trust into three separate trusts
The IRS approved a proposed pro rata division of an irrevocable trust created before September 25, 1985, into three separate trusts for three grandchildren and their descendants. The ruling…
PLR 1245006: IRS approves grantor-trust treatment and a post-death basis adjustment
The IRS ruled that a foreign taxpayer would be treated as the owner of an irrevocable trust during the taxpayer's lifetime because the trust's income had to be paid to the taxpayer and its principal…
PLR 1244004: IRS approves liquidating-trust and partnership-termination treatment
A limited partnership sold its assets and wanted to distribute the proceeds and dissolve, but it faced known and possible contingent liabilities. It formed a trust to hold cash, resolve those…
PLR 1238004: IRS approves a two-trust division and related tax treatment
The IRS approved a proposed division of an irrevocable trust into two separate trusts, one for each of the settlor's children and that child's descendants. The ruling concluded that the division…
Trust and life insurance rulings for an irrevocable trust
A taxpayer requested rulings on two irrevocable trusts, including a trust that would acquire a life insurance policy from another trust. The IRS addressed grantor trust treatment, beneficiary…
PLR 1226019: IRS approves a voting trust as an S corporation shareholder
The IRS rules that a proposed voting trust will be classified as an investment trust for federal income tax purposes. It also rules that the trust will be a qualified voting trust and a permitted S…
PLR 1225004: IRS approves charitable deduction for trust distribution under a limited power
An irrevocable trust asked whether a distribution of its income to charitable organizations under a beneficiary's limited power of appointment would qualify for a charitable deduction. The IRS…
PLR 1223012: IRS approves a tax-neutral trust division and modification
The IRS approved corrections to two scrivener's errors in an irrevocable trust and a pro rata division of the trust into two successor trusts for separate family lines. The IRS ruled that the…
PLR 1222005: IRS approves a pooled fund's building reacquisition and related tax treatment
The IRS ruled on a tax-exempt organization’s plan to reacquire certain building interests from a pooled income fund in partial satisfaction of the fund’s debt. The IRS concluded that the…
PLR 1216034: IRS rules on trust ownership, S corporation status, and estate inclusion
The IRS considered a domestic trust that was created for an individual who also served as trustee and beneficiary. The individual could withdraw contributions, subject to an annual lapse rule, and…
PLR 1202019: IRS grants a trust more time to elect a charitable deduction
The IRS granted a trust an extension of time to make an election under IRC section 642(c)(1). The election would treat charitable contributions paid to a tax-exempt foundation in a later tax year as…
CCA 1138033: IRS considered disregarding an abusive trust arrangement
Chief Counsel Advice concerned a case that the authors believed involved an abusive trust arrangement. They stated that the IRS should possibly disregard the trust and disallow deductions for the…
PLR 1133004: Trust reformation approved for charitable remainder unitrust
The IRS approved a court-ordered reformation of a trust from a net income with makeup charitable remainder unitrust to a standard charitable remainder unitrust. The ruling states that the trust was…
PLR 1132005: Late charitable deduction election granted to an estate or trust
The IRS granted a trust 120 more days to elect to treat a charitable contribution made in one tax year as paid in the prior tax year. The trustee intended to make the election but failed to do so on…
PLR 1129026: Trust granted more time to make a 65-day election
A trust made a distribution during the first 65 days of a tax year and reported it on the prior year's return, but did not timely make the election required under IRC § 663(b). The IRS concluded…
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.…
PLR 1126007: Annuity-purchase provision did not disqualify a CRAT
A taxpayer planned to create a charitable remainder annuity trust funded with appreciated real property. The proposed trust would allow its trustee to use part of the trust assets to buy an annuity…
PLR 1119005: IRS approved separate shares and successor QSST treatment
A trust that held S corporation stock was divided into two shares after the death of an income beneficiary. Each share was dedicated to a different successor income beneficiary, with income and…
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 1116005: IRS treated an IRA transfer to a special needs trust as non-sale
The IRS considered a disabled taxpayer who was eligible for public benefits and planned to transfer an inherited IRA share to a newly established special needs trust. The trust would benefit the…
PLR 1116002: IRS restored an S corporation election after an inadvertent trust transfer
The IRS considered an S corporation whose stock was transferred from a grantor trust into two trusts intended to be qualified subchapter S trusts. One trust was eligible but did not make a timely…
IRS grants extra time for a trust’s 65-day election
The IRS granted a trust 120 additional days to make the section 663(b) election for a distribution made during the first 65 days of a tax year. The trust intended to treat the distribution as paid…
PLR 1113040: IRS approves a charitable remainder trust reformation and finds no self-dealing
A married couple asked whether a state-court reformation of their charitable remainder trust would preserve the trust's status as a charitable remainder unitrust and avoid self-dealing excise taxes.…
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.