News & Analysis as of

Private Letter Rulings

Making Use of a Deceased Spouse’s Unused Estate Tax Exemption Simplified

by Genova Burns LLC on

The election for married couples to elect portability of the Federal Estate Tax Exemption was introduced in late 2010 when the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act (“TRUIRJCA”) was signed...more

Virginia Imposes Fees for Requests for Certain Actions by the Departments

by Williams Mullen on

Starting July 1, 2017, taxpayers that request an “Offer in Compromise with respect to doubtful collectability under Sec. 58.1-15, a Ruling Letter from the Commissioner under Sec. 58.1-203, a local tax advisory opinion under...more

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Debt Dialogue: May 2017 - The 2016 IRS Regulations Regarding Partnership Liabilities and Disguised Sale Rules

The Internal Revenue Service (IRS) issued regulations last October (the 2016 Regulations) that significantly alter the landscape of allocations of partnership liabilities and the disguised sale rules. The 2016 Regulations...more

IRS Issues Guidance on “North-South” Transactions

by Proskauer - Tax Talks on

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

by Shearman & Sterling LLP on

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

Financial Services Weekly News - May 2017

by Goodwin on

Editor's Note - In This Issue. The Senate confirmed Jay Clayton as the new chairman of the U.S. Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC) released its final handbook for...more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

Copying is Best in the ING World

by Bryan Cave on

Not only is strict adherence to the structure set out in prior favorable rulings best, it is essential when it comes to obtaining a favorable ING ruling. The provisions in the trust document need to carve a very fine line...more

IRS Limiting GST Private Letter Rulings and Presubmission Conferences

by Charles (Chuck) Rubin on

At a recent Federal Bar Association Tax Law Conference, an IRS Chief Counsel branch chief advised that due to budget cuts: a. The IRS has temporarily suspended issuing private letter rulings regarding modifications to...more

Tax Guidance to Slow Under Trump. Even More Emphasis on Letter Rulings in Bond Transactions?

As the Trump administration attempts to substantially reduce the amount of federal regulations, both the Deputy Tax Legislative Counsel of the Treasury Department and an Associate Chief Counsel at the Internal Revenue Service...more

Wealth Management Update - February 2017

by Proskauer Rose LLP on

February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

IRS Permits Trust Division Without Adverse Federal Tax Consequences

by Charles (Chuck) Rubin on

In Private Letter Rulings 201702005 and 201702006, the IRS favorably ruled on federal tax consequences of a proposed trust division. But for a minor change in facts, the two rulings are identical, so we will focus only on...more

Holiday Horror Series: Part 2- Hectic Holiday Rollovers

by Weintraub Tobin on

With the holidays upon us, we all can relate to how easy it is to mistakenly overlook important things amidst the cheery holiday hustle and bustle: leaving the Christmas ham in the oven a few hours too long, forgetting to...more

Private Ruling Exempts Property Management Services from Self-Dealing

A new private ruling may be of great interest to clients with substantial real estate interests who wish to contribute one or more properties to a family foundation. The ruling suggests that payment by the foundation to a...more

IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing...

by Dechert LLP on

The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more

IRS Permits Self-Certification for Late Rollovers to Qualified Retirement Plans

by McCarter & English, LLP on

Generally, an amount distributed from a qualified retirement plan (including an employer-sponsored plan and an IRA) is excluded from income if it is transferred to another plan within 60 days following receipt. In the past,...more

Wealth Management Update - October 2016

by Proskauer Rose LLP on

October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more

IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

by Goodwin on

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

Financial Services Weekly News - September 2016 #3

by Goodwin on

Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

IRS to Update 1967 Revenue Ruling Relating to Change of Domicile

The Internal Revenue Service (the “IRS”) has announced plans to update Revenue Ruling 67-390, which requires an organization to “re-apply” for tax-exemption if it changes its corporate structure, including in situations...more

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

by McDermott Will & Emery on

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

Final Regulations Clarify the Definition of “Real Property” Under the REIT Rules

by Morrison & Foerster LLP on

On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more

IRS Makes Late Rollovers Easier

by Snell & Wilmer on

Generally, distributions from a qualified retirement plan that are eligible for rollover must be rolled over within 60 days of the date on which the distribution occurs. If a taxpayer did not complete the rollover within 60...more

Treasury Department Issues Final Regulations on Real Property Definition for REIT Purposes

by Latham & Watkins LLP on

Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules. On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more

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