Letter Rulings

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Richard Fox lends us a cautionary tale about the need for proper administration of Charitable Trusts. A recent Private Letter Ruling demonstrates the dire consequences of retaining the wrong person for administration.
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David Wheeler Newman provides his analysis of the recent PLR that has planners re-thinking how they use CRTs in their planning.
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Richard Fox analyzes and clarifies a recent PLR involving a CRT. There are interesting opportunities to explore subsequent to this ruling.
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Richard Fox provides a thorough view of the self-dealing rules by analyzing two recent Private Letter Rulings.

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23 Dec 2014 | Letter Rulings | National Publication | News story

PLR allows reformation of CRT.

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In this PLR the IRS offers clarification on a number of private foundation issues: excess business holdings; UBTI; and self-dealing. Interesting facts and circumstances lead to a very favorable outcome.

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When is an irrevocable trust revocable? The recently adopted Uniform Trust Code (UTC) was supposed to make all of this more clear, but a recent case in New Mexico has muddied the waters for all practitioners.

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15 May 2014 | Letter Rulings | National Publication | News story

In a recent ruling, the tax court allowed the transfer of assets from a charitable trust to a private foundation that were both governed by substantially the same family. The courts still held, among other things, that there was no act of self-dealing, there were no...

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A substantial and material change in the sources of support of a public charity described in IRC Sections 170(b)(1)(A)(vi) or 509(a)(2), which are dependent on a sufficient amount of public support for their public charity status, may potentially cause an...

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In recently issued Ltr. Rul. 201323007, the taxpayer created a charitable lead annuity trust ("CLAT"), where the beneficiary of the income interest was a private foundation. The foundation was established by the taxpayer and his spouse and the taxpayer, his spouse,...

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IRS section 642(c)(1) provides that estates and certain trusts can elect to deduct charitable contributions made in the current year on their prior year's income tax return. In this case, the IRS has ruled privately that a trust that had intended but failed to make...

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30 Oct 2013 | Letter Rulings | National Publication | News story

The Service has ruled privately that a court ordered reformation of a net income with make-up provision charitable remainder unitrust to bring the trust into compliance with current law will not cause it to fail to qualify as charitable remainder unitrust under I.R....

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19 Aug 2013 | Letter Rulings | National Publication | News story

The IRS has approved the reformation of a testamentary charitable remainder unitrust (CRUT) that was funded via formula in the trustor's revocable living trust in an amount that exceeded the unified credit exclusion amount provided under law at the time of the...

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19 Aug 2013 | Letter Rulings | National Publication | News story | 1 comments

The IRS has ruled privately that a private foundation's ownership interest in an LLC that is taxed as a partnership and that operates solely as a hedge fund will not generate unrelated business taxable income to the foundation, will not subject the foundation to the...

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19 Aug 2013 | Letter Rulings | National Publication | News story

In most cases the PGDC does not comment on rulings involving denials of tax-exempt status unless they involve high-profile issues or concepts of general application. In this case, a corporation organized as a cooperative that facilitates and organizes transactions...

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14 Aug 2013 | Letter Rulings | National Publication | News story

The IRS has approved a court ordered reformation of a net income with make-up provision charitable remainder unitrust to eliminate a requirement that would require the trustee to treat any deficiency account balance as a liability when valuing the trust for purposes...

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29 Jul 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that an assignment by a trustee of two IRAs to two charitable organizations from the residue of an estate would be income in respect of a decedent only to the charities in the amounts received by each. Of course, this is the ideal result...

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24 Jul 2013 | Letter Rulings | National Publication | News story | 1 comments

The IRS has ruled privately that a private foundation's investment in Class A membership interests in an LLC that operates a hedge fund and is treated as a partnership for federal tax purposes will not generate unrelated business taxable income to the foundation,...

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14 Jul 2013 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a private foundation may have an additional five years to dispose of its excess business holdings. The foundation stated that despite making a diligent effort during the initial five-year period, disposition was not possible (except...

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Define: Letter Rulings

A private letter ruling (PLR or Ltr. Rul.) is a written statement issued by the IRS to a taxpayer that interprets and applies tax laws to the taxpayer’s specific set of facts. It is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer’s return is filed. It is issued in response to a written request submitted by a taxpayer and is binding on the IRS if the taxpayer fully and accurately described the proposed transaction in the request and carries out the transaction as described. A private letter ruling may not be relied on as precedent by other taxpayers or IRS personnel. Private letter rulings are generally made public after all information has been redacted that could identify the taxpayer to whom it was issued.

Recent activity

Settlor Not Claiming Charitable Deduction Allows Charitable Remainder Trust to Escape Private Foundation Excise Tax Rules

Can Charitable Remainder Trusts Avoid The Self-Dealing Rules?

Recently Issued PLRs Offer Cautionary Tale to Trustees Failing to Administer Charitable Remainder Trusts in Accordance with Governing Instrument

Private Foundation Permitted to Own Hedge Fund

IRS Approves Private Foundation's Investment in LLC

Issuance of Units from Organization's Endowment Fund to CRT Does Not Cause UBTI