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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QTIP severance confines gift and estate consequences to the disclaimed trust
An estate had elected qualified terminable interest property treatment for a marital trust benefiting the surviving spouse. The trustee proposed dividing the GST nonexempt portion into two trusts…
Trust may use a three-year average for its unitrust payment
A trust that was irrevocable before September 25, 1985 had previously converted its income distributions to a unitrust amount. The trustee proposed changing the calculation from the prior year's…
Retained powers kept trust transfers incomplete gifts
A grantor created an irrevocable trust that could distribute property to her and several charities. She retained veto powers over distributions and a testamentary limited power to appoint the…
Retained powers kept trust transfers incomplete gifts
A grantor created an irrevocable trust that could distribute property to him and several charities. He retained veto powers over distributions and a testamentary limited power to appoint the…
Trust division preserved tax treatment and asset basis
A trust for a daughter and her descendants proposed dividing its assets equally between two successor trusts, one for each family line. The daughter would remain a beneficiary of both trusts, and…
Closed years preserved gift splitting, later GRAT elections failed
A husband created a family trust for his wife and descendants and several grantor retained annuity trusts whose remainders passed to that family trust. The spouses elected gift splitting and made or…
Trust modification preserves generation-skipping tax exemption
A trust created before September 25, 1985, was scheduled to distribute its assets outright to three great-grandchildren. A state court modification instead placed each beneficiary's share in a…
Separate beneficiary trusts preserve generation-skipping tax exemption
A trust created before September 25, 1985, was due to distribute its assets outright to two great-grandchildren. A state court modification instead placed each beneficiary's share in a separate…
Trust reformation preserves GST exemption and creates no gift
A trust created before September 25, 1985, had ambiguous provisions governing who would receive the remainder if its primary beneficiary had no descendants. A proposed judicial reformation clarified…
Trust settlement preserves GST exemption and avoids gift and income tax
Beneficiaries of a pre-September 25, 1985 testamentary trust settled extensive litigation over trust administration and a no-contest clause. Two beneficiaries and their issue would terminate their…
Surviving spouse's proposed securities disclaimers qualify under section 2518
A surviving spouse planned to disclaim specified securities received through an outright lifetime transfer and a joint account that became a completed gift at the other spouse's death. He had traded…
Trust division and court modifications preserve grandfathered GST status
A will created a trust before September 25, 1985, but left ambiguity about when the trust ended and how its assets passed after the original beneficiary's death. A state court construed the trust to…
Trust division and court modifications preserve grandfathered GST status
A will created a trust before September 25, 1985, but left ambiguity about when the trust ended and how its assets passed after the named family members died. A state court construed the trust to…
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…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Coordinated trust land sale preserves transfer-tax treatment
Two related, pre-September 25, 1985 trusts jointly owned intermingled farm acreage and proposed a coordinated sale to a partnership owned by a descendant and trust beneficiary. The price was…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved farm sale preserves grandfathered trusts’ GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned adjoining and sometimes landlocked parcels of a farm. Their trustees proposed a coordinated sale to a limited partnership owned…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
Court-approved trust land sale preserves GST exemption
Two irrevocable trusts created before September 25, 1985 jointly owned contiguous farm property and proposed a coordinated sale to a limited partnership owned by a descendant. The price was…
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…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
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.