Private Letter Rulings

News & Analysis as of

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

IRS Issues Private Letter Ruling on Treatment of Managed Professional Corporations

The Internal Revenue Service (“IRS”) recently published a private letter ruling (“PLR”) that permits a practice management corporation to include two managed professional corporations as members of the management...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

FDIC Issues Private Letter to Elaborate on Brokered Deposit FAQ

On February 4, representatives of the Federal Deposit Insurance Corporation (FDIC) sent a letter to David Hanrahan, the president and CEO of Capital Bank of New Jersey, in which they elaborated on a particular question and...more

IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the...more

IRS Rules on Domesticated Organization and Tax-Exempt Status

Late last year, the Internal Revenue Service (“IRS”) issued a letter ruling, PLR 201446025, providing that, in certain instances, a nonprofit corporation exempt under Section 501(c)(3) of the Internal Revenue Code of 1986, as...more

IRS private letter ruling on non-conventional real estate assets enables taxpayer to convert to REIT: key points

The Internal Revenue Service recently released a private letter ruling regarding the treatment of certain assets as qualifying “real estate” for real estate investment trust (REIT) purposes. That ruling effectively enabled...more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

No Private Letter Rulings in These Estate Planning Areas

Taxpayers who have questions about the applicability of tax law can submit a Private Letter Ruling request to the IRS. If the IRS rules, then the taxpayer can rely on the ruling as to how the law applies to their situation...more

New IRS Ruling Benefits Investor-Owned Hospitals

Last month, the Internal Revenue Service (IRS) issued a private letter ruling providing a tax benefit to hospitals that own physician practices. The ruling should be of particular interest to hospitals with physician...more

Department Shifts Position on Sourcing of Intangibles

While the Department’s Information Notice focuses primarily on the sourcing of revenues from services, it also addresses the sourcing of receipts from intangibles – in a manner seeming to be directly at odds with previously...more

IRS Private Letter Ruling Addressing Captive Professional Corporations Could Result in Significant “Consolidated” Tax Savings

On December 19, 2014, the Internal Revenue Service published PLR 201451009, favorably ruling that a for-profit management company could include its captive professional corporation as a member of its consolidated group for...more

High Net Worth Family Tax Report, Vol. 9, No. 3

In This Issue: - Tax planning strategies to consider before the end of the year - The IRS announces inflation-adjusted amounts for 2015 - Case update: Taxpayer’s deduction for interest capitalized in loan...more

Tennessee Tax Department Releases Letter Rulings

The Tennessee Department of Revenue recently released several Letter Rulings analyzing various Tennessee tax issues, including the application of sales and use taxes to cloud collaboration services and software consulting...more

IRS Rules That Some Basis in Solar System Must Be Allocated to Structural Functions

On October 31, the IRS released Private Letter Ruling 201444025, which was addressed to a manufacturer of solar systems that are mounted on real estate. The nature of the real estate, along with many other interesting facts,...more

Tennessee SaaS Ruling Highlights Telecommunications Concerns for SaaS Providers

The Tennessee Department of Revenue recently released Letter Ruling No. 14-05, in which it considered whether certain cloud collaboration services are subject to the state’s sales tax. At a high level, the provider’s...more

Four Trends in Master Limited Partnership M&A in 2014

MLP merger and acquisition activity can take a number of different forms to unlock value for sponsors and unitholders. Background - In the first half of 2014, master limited partnership (MLP) mergers and...more

IRS Affirms Treatment of Short Sales for UBTI Purposes

Since there are many hedge funds that utilize short selling as part of their investment strategy, it is important for hedge fund investors, including tax exempt organizations, to understand the U.S. tax treatment of these...more

Are REITs a Viable Strategy for Communications Companies?

Windstream Holdings, Inc. recently announced plans to spin off its copper, fiber and other fixed real estate assets into an independent publicly traded real estate investment trust (REIT). Windstream received a private letter...more

Five New IRS Private Letter Rulings Confirm IRS’s Position Allowing Retiree Cashouts

We reported in 2012 on two private letter rulings (“PLRs”) issued by the IRS (PLR 201228045 and PLR 201228051) blessing certain retiree cashout programs. A retiree cashout program is a de-risking strategy used by defined...more

Control Is Everything

In Private Letter Ruling 201423043, (“PLRs” only apply to the taxpayer involved but are often used as “guidance”, and not “precedent”, by taxpayers and the IRS.) the IRS ruled that a surviving spouse could roll over her...more

IRS Issues Favorable Private Letter Ruling to Data Center REIT

On June 6, 2014, the Internal Revenue Service (IRS) released Private Letter Ruling 201423011 (the PLR), confirming that income from certain data center services can constitute “rents from real property” for purposes of the...more

IRS Releases Additional Rulings on Lump-Sum Windows

The practice of offering lump-sum distributions has become increasingly popular among defined benefit plan sponsors looking to decrease volatility or other defined benefit plan risks. In some situations, plan sponsors offer...more

IRS Issues Another Significant Ruling on Spin-off of Real Estate

In certain recent transactions, a corporation distributes a subsidiary corporation holding the distributing corporation’s real estate assets to the distributing corporation’s shareholders in a tax-free “spin-off.” Not only...more

The Oklahoma MLP Quarterly - 1Q 2014

The Oklahoma MLP Quarterly highlights changes in taxation, law and capital markets that affect master limited partnerships who have headquarters located in, or significant contacts with, Oklahoma. The publication is...more

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