All private letter rulings
are published and are accessible by the general public.
Until the recent private letter rulings
, insight into how the IRS views the requirements of Sec.
Private letter rulings
and licensing reduce uncertainty even further by enabling taxpayers to obtain an individual application of the law to their specific facts before the transactions are undertaken.
Citing Revenue Ruling 2005-36, the taxpayer was also given a similar "qualified disclaimer" in Private Letter Ruling
201245004 (November 9,2012)--overlooking the fact that in the 2012 case, the spousal beneficiary collected more than the RMD.
Due to the nature of private letter rulings
, it is very difficult to view previous private letter rulings
concerning shipping companies and whether or not their activities are incidental to the international operation of ships.
The private letter rulings
deal with the effects of IRS gift tax rules on trusts that use trust beneficiary committees to direct trust distributions, officials say.
Two private letter rulings
(PLR 9448035 and 9433016) permitted lease language to be incorporated into QPRT documents.
The Friendly Hills and Facey private letter rulings
issued earlier this year established a 20 percent safe harbor for such involvement.
NASDAQ: DTV) announced today that Liberty Media Corporation ("Liberty Media") has received a private letter ruling
from the Internal Revenue Service ("IRS") relating to the tax treatment of various aspects of the split-off of Liberty Entertainment, Inc.
In some instances, private letter rulings
lead to the IRS publishing a Revenue Ruling for common usage: "a Revenue Ruling often results from a specific taxpayer's request for a letter ruling .
Yet, in Private Letter Ruling
200121031, the IRS addressed damages for a disease, finding a recovery against an asbestos manufacturer to be excludable, even though there was no physical contact with the plaintiff.
The site's databases, which are updated frequently, include tax case law from 1990 to present, revenue rulings and revenue procedures from 1954 to present, private letter rulings
from 1979 to present, and numerous other IRS administrative materials with varying date coverage.
He also encouraged TEI members to provide comments on the IRS's policy for issuing section 355 private letter rulings
, which was announced in Revenue Procedure 2003-48.
If they are unable to find court cases that address the issue at hand, they may need to turn to private letter rulings
or to IRS general counsel memoranda (GCMs), which are background documents the IRS uses to support a ruling.
For example, the IRS issued a number of private letter rulings
to taxpayers that sanctioned a hospital's sale of part of its operations revenue stream to a joint venture between the hospital and medical staff physicians.