Letter Rulings

Highlighting Letter Rulings

Service Approves CRAT Provision Permitting Purchase of Commercial Annuity Contract to Cover Annual Annuity Amount

The Service has ruled privately that a charitable remainder annuity trust can include a provision that grants the trustee the discretion to provide for the annuity payment to the income recipient by allocating a portion of the trust assets to purchase an annuity contract which...

SO Permitted to Specify Supported Organizations by Class or Purpose

The IRS has ruled privately that a supporting organization that amends its Articles of Incorporation to enable it to identify the organizations it will support by class or purpose rather than by name will not adversely affect its status as a Type 1 supporting...

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		Rated
	13 Feb 2012 \| Letter Rulings \| National Publication \| News story Sale of Property to Disqualified Person with Promissory Note Not Self... The Service has ruled privately that a sale of real property by an estate from which a private foundation has an expectancy to a disqualified person in exchange for a promissory note is not a direct or indirect act of self-dealing because it qualifies as a...	0
	6 Feb 2012 \| Letter Rulings \| National Publication \| News story Scholarship Awards Excludable from Income of Recipients The IRS has ruled privately that scholarship awards made by a private foundation are excludable from the gross income of the recipients under section 117 of the Code.	0
	6 Feb 2012 \| Letter Rulings \| National Publication \| News story Scholarship Awards Not Taxable Expenditures The IRS has ruled privately that a private foundation's scholarship grants to artists are not taxable expenditures under section 4945.	0
	17 Jan 2012 \| Letter Rulings \| National Publication \| News story Trust Granted Extension to Make Election The IRS has ruled privately that a charitable trust that intended but failed to make an election to treat a contribution as having been paid in the prior year is granted an extension to make the election	0
	9 Jan 2012 \| Letter Rulings \| National Publication \| News story Use of Debt by Private Operating Foundation for Set-Asides is... The Service has ruled privately that a private foundation's use of the proceeds of loans from a local financial institution to satisfy all or a portion of either the Initial set-aside amount and/or the additional set-aside amount for the purpose of constructing...	0
	14 Nov 2011 \| Letter Rulings \| National Publication \| News story Transfer of Limited Partnership Interest Redemption Proceeds to... The IRS has ruled privately that proposed sales of limited partnership interests by an executor back to the limited partnerships followed by the transfer of the cash sales proceeds to a testamentary charitable lead unitrust qualifies for the estate administration...	0
	1 Nov 2011 \| Letter Rulings \| National Publication \| News story Net Profits Interest in Oil and Gas Not UBI The IRS has ruled privately that the debt of a third party oil and gas working interest owner will not constitute acquisition indebtedness to a private foundation under section 514 with respect to the foundation's net profits interest royalty that is...	4
	29 Aug 2011 \| Letter Rulings \| National Publication \| News story LLC Created by Private Operating Foundation to Build Religious School... The IRS has ruled privately that a private operating foundation's creation and funding of a limited liability company for the purpose of acquiring land and building a school to be operated by a separate, unrelated nonprofit corporation as a religious...	0
	23 Aug 2011 \| Letter Rulings \| National Publication \| News story Service Approves Conversion of Supporting Organization to Private... The IRS has ruled privately that a Type I supporting organization as described under section 509(a)(3) can forgo its status as such to become a private foundation without giving rise to excess benefit transactions, causing a prohibited act of self-dealing or taxable...	0
	22 Aug 2011 \| Letter Rulings \| National Publication \| News story IRS Approves Reformation to Correct Scrivener's Error The IRS has ruled privately that a charitable remainder unitrust can be reformed ab initio to remove a net income with make-up provision that had inadvertently been included by the drafting attorney without adversely affecting the qualification of the trust...	0
	18 Aug 2011 \| Letter Rulings \| National Publication \| News story Contribution of Broadcast Station Licenses Deductible The IRS has ruled privately that a donor can claim and income tax charitable deduction for the contribution of television broadcast licenses provided the donor properly substantiates them. Further ruled, the licenses are treated as long-term capital assets for...	0
	11 Aug 2011 \| Letter Rulings \| National Publication \| News story Amendment of Supporting Org's Articles of Incorporation Approved The IRS has ruled privately that an amendment by a supporting organization of its articles of incorporation to add an affiliated trust of a supported corporation will not adversely affect the supporting organization's exempt status.	0
	3 Aug 2011 \| Letter Rulings \| National Publication \| News story Transfer of Property Between Private Foundation and Former Trustee... The IRS has ruled privately that a transfer of property between a private foundation and a former trustee is not a prohibited act of self-dealing under section 4941 because the trustee was no longer a disqualified person at the time of the transfer.	0
	26 Jul 2011 \| Letter Rulings \| National Publication \| News story Promissory Note Payments From Corporation to Private Foundation Not... The IRS has ruled privately that promissory note payments from a privately held corporation to a private foundation following the period of estate administration terminations will not constitute a prohibited act of self-dealing because the transaction satisfies...	0
	18 Jul 2011 \| Letter Rulings \| National Publication \| News story Rental Income Not Unrelated Business Income The Service has ruled privately that rental income derived by a charitable organization from the use of real...	0
	18 Jul 2011 \| Letter Rulings \| National Publication \| News story Ownership of 100% of Company Stock by Private Foundation Not Excess... The IRS has ruled privately that a private foundation's ownership of a 100 percent the stock of a company will not be considered a business enterprise and excess business holdings under section 4943(c) of the Code because at least 95 percent of the company...	0
	5 Jul 2011 \| Letter Rulings \| National Publication \| News story Grants from Private Foundation's Scholarship Program Not Taxable The Service has ruled privately that scholarship awards from a private foundation will not be considered taxable expenditures under section 4945(g)(1) and are excludable from the gross income of recipients subject to the limitations provided by...	0
	5 Jul 2011 \| Letter Rulings \| National Publication \| News story Service Approves CRAT Provision Permitting Purchase of Commercial... The Service has ruled privately that a charitable remainder annuity trust can include a provision that grants the trustee the discretion to provide for the annuity payment to the income recipient by allocating a portion of the trust assets to purchase an annuity...	0
	26 Jun 2011 \| Letter Rulings \| National Publication \| News story Service Approves Qualified Reformation to Create CRT The Service has ruled privately that a reformation of a testamentary trust to qualify as a charitable remainder trust is qualified reformation and qualifies for an estate tax charitable deduction provided the reformation is effective under State law.	0
	22 Jun 2011 \| Letter Rulings \| National Publication \| News story SO Permitted to Specify Supported Organizations by Class or Purpose The IRS has ruled privately that a supporting organization that amends its Articles of Incorporation to enable it to identify the organizations it will support by class or purpose rather than by name will not adversely affect its status as a Type 1...	0

7520 Rates: February 1.4% January 1.4% December 1.6%

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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.

"David, These PLR's were secured by my company, in partnership with a leading life insurance company and national nonprofit. I would be happy to..." from Metamor.

"David, Call me Monday to Discuss 615-377-6780 ext 17 Erik" from Erik Faulk.

"I have a school that is a client that is lookign into using this approach of reinsurance for gift annuities. They are worried that there are some..." from AGA101.

"A word of caution here is warranted: we have researched this well and have found a NY case that states that a commercial annuity (VA and SPA) DOES..." from Ben Robinson.

"Mr. Clontz" from Joseph Pratt.

"Our team uses this approach with CHA's. We have done numerous reconciliations and comparison. There are some issues but mostly it depends upon the..." from Ben Robinson.

"It is my understanding that the charities that invest the dononr's gift and pay the income out of earnings usually have to hold the funds until the..." from disaacson.

"I work with a non profit that does these types of transactions frequently (Over 50 in the last year). We also reinsure 98% of these. Depending on the..." from Erik Faulk.

"I have a donor who paid in full for a $75,000 commercial mutual fund/annuity, with a 14% payout to him. He then made our non profit organization the..." from Judith Lopacki.

" [For other states where it is an option, if a charity reinsures its liability created by the Charitable Gift Annuity, logic would dictate that the..." from Vaughn Henry.

"The donor's deduction isn't affected if the charity uses a commercial annuity (most often a single premium immediate annuity ~ SPIA) to backstop the..." from Vaughn Henry.

"Very good article on reinsurance and its effect on the donor's deduction by Bryan Clontz at http://www.pgdc.com/pgdc/article/2006/03/charitable-gift-..." from Marc Hoffman.

"The ruling indicates that the Donor will be aware that the Charity will use the gifted assets to purchase a commercial annuity from the Insurer for..." from Joseph Pratt.

"This is wonderful news, except if you live in New Hampshire. The state of NH, in its infinite wisdom, does not allow charities to buy commercial..." from Stephen Mathieu.

GSTT - Grandfathered Trust Creates Charitable Subtrust

"I wonder how many of these "Cheney bashers" broadcast their charitable gifts to minimize criticism for advocating torture, limitation of civil rights..." from gas.

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		Rated
	13 Feb 2012 \| Letter Rulings \| National Publication \| News story Sale of Property to Disqualified Person with Promissory Note Not Self... The Service has ruled privately that a sale of real property by an estate from which a private foundation has an expectancy to a disqualified person in exchange for a promissory note is not a direct or indirect act of self-dealing because it qualifies as a...	0
	6 Feb 2012 \| Letter Rulings \| National Publication \| News story Scholarship Awards Excludable from Income of Recipients The IRS has ruled privately that scholarship awards made by a private foundation are excludable from the gross income of the recipients under section 117 of the Code.	0
	6 Feb 2012 \| Letter Rulings \| National Publication \| News story Scholarship Awards Not Taxable Expenditures The IRS has ruled privately that a private foundation's scholarship grants to artists are not taxable expenditures under section 4945.	0
	17 Jan 2012 \| Letter Rulings \| National Publication \| News story Trust Granted Extension to Make Election The IRS has ruled privately that a charitable trust that intended but failed to make an election to treat a contribution as having been paid in the prior year is granted an extension to make the election	0
	9 Jan 2012 \| Letter Rulings \| National Publication \| News story Use of Debt by Private Operating Foundation for Set-Asides is... The Service has ruled privately that a private foundation's use of the proceeds of loans from a local financial institution to satisfy all or a portion of either the Initial set-aside amount and/or the additional set-aside amount for the purpose of constructing...	0
	14 Nov 2011 \| Letter Rulings \| National Publication \| News story Transfer of Limited Partnership Interest Redemption Proceeds to... The IRS has ruled privately that proposed sales of limited partnership interests by an executor back to the limited partnerships followed by the transfer of the cash sales proceeds to a testamentary charitable lead unitrust qualifies for the estate administration...	0
	1 Nov 2011 \| Letter Rulings \| National Publication \| News story Net Profits Interest in Oil and Gas Not UBI The IRS has ruled privately that the debt of a third party oil and gas working interest owner will not constitute acquisition indebtedness to a private foundation under section 514 with respect to the foundation's net profits interest royalty that is...	4
	29 Aug 2011 \| Letter Rulings \| National Publication \| News story LLC Created by Private Operating Foundation to Build Religious School... The IRS has ruled privately that a private operating foundation's creation and funding of a limited liability company for the purpose of acquiring land and building a school to be operated by a separate, unrelated nonprofit corporation as a religious...	0
	23 Aug 2011 \| Letter Rulings \| National Publication \| News story Service Approves Conversion of Supporting Organization to Private... The IRS has ruled privately that a Type I supporting organization as described under section 509(a)(3) can forgo its status as such to become a private foundation without giving rise to excess benefit transactions, causing a prohibited act of self-dealing or taxable...	0
	22 Aug 2011 \| Letter Rulings \| National Publication \| News story IRS Approves Reformation to Correct Scrivener's Error The IRS has ruled privately that a charitable remainder unitrust can be reformed ab initio to remove a net income with make-up provision that had inadvertently been included by the drafting attorney without adversely affecting the qualification of the trust...	0
	18 Aug 2011 \| Letter Rulings \| National Publication \| News story Contribution of Broadcast Station Licenses Deductible The IRS has ruled privately that a donor can claim and income tax charitable deduction for the contribution of television broadcast licenses provided the donor properly substantiates them. Further ruled, the licenses are treated as long-term capital assets for...	0
	11 Aug 2011 \| Letter Rulings \| National Publication \| News story Amendment of Supporting Org's Articles of Incorporation Approved The IRS has ruled privately that an amendment by a supporting organization of its articles of incorporation to add an affiliated trust of a supported corporation will not adversely affect the supporting organization's exempt status.	0
	3 Aug 2011 \| Letter Rulings \| National Publication \| News story Transfer of Property Between Private Foundation and Former Trustee... The IRS has ruled privately that a transfer of property between a private foundation and a former trustee is not a prohibited act of self-dealing under section 4941 because the trustee was no longer a disqualified person at the time of the transfer.	0
	26 Jul 2011 \| Letter Rulings \| National Publication \| News story Promissory Note Payments From Corporation to Private Foundation Not... The IRS has ruled privately that promissory note payments from a privately held corporation to a private foundation following the period of estate administration terminations will not constitute a prohibited act of self-dealing because the transaction satisfies...	0
	18 Jul 2011 \| Letter Rulings \| National Publication \| News story Rental Income Not Unrelated Business Income The Service has ruled privately that rental income derived by a charitable organization from the use of real...	0
	18 Jul 2011 \| Letter Rulings \| National Publication \| News story Ownership of 100% of Company Stock by Private Foundation Not Excess... The IRS has ruled privately that a private foundation's ownership of a 100 percent the stock of a company will not be considered a business enterprise and excess business holdings under section 4943(c) of the Code because at least 95 percent of the company...	0
	5 Jul 2011 \| Letter Rulings \| National Publication \| News story Grants from Private Foundation's Scholarship Program Not Taxable The Service has ruled privately that scholarship awards from a private foundation will not be considered taxable expenditures under section 4945(g)(1) and are excludable from the gross income of recipients subject to the limitations provided by...	0
	5 Jul 2011 \| Letter Rulings \| National Publication \| News story Service Approves CRAT Provision Permitting Purchase of Commercial... The Service has ruled privately that a charitable remainder annuity trust can include a provision that grants the trustee the discretion to provide for the annuity payment to the income recipient by allocating a portion of the trust assets to purchase an annuity...	0
	26 Jun 2011 \| Letter Rulings \| National Publication \| News story Service Approves Qualified Reformation to Create CRT The Service has ruled privately that a reformation of a testamentary trust to qualify as a charitable remainder trust is qualified reformation and qualifies for an estate tax charitable deduction provided the reformation is effective under State law.	0
	22 Jun 2011 \| Letter Rulings \| National Publication \| News story SO Permitted to Specify Supported Organizations by Class or Purpose The IRS has ruled privately that a supporting organization that amends its Articles of Incorporation to enable it to identify the organizations it will support by class or purpose rather than by name will not adversely affect its status as a Type 1...	0

Letter Rulings

Highlighting Letter Rulings

Service Approves CRAT Provision Permitting Purchase of Commercial Annuity Contract to Cover Annual Annuity Amount

SO Permitted to Specify Supported Organizations by Class or Purpose

Already a member?

Learn, Share, Gain Insight, Connect, Advance

Define: Letter Rulings

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Issuance of Units by University to CRTs Does Not Produce Unrelated Business Income

Grants to Foreign Charities are Qualifying Distributions

Charitable Deduction for Artwork

Reinsurance of CGA Not Commercial Insurance or UBI

GSTT - Grandfathered Trust Creates Charitable Subtrust

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