News & Analysis as of

Internal Revenue Service Tax Liability Private Letter Rulings

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Gray Reed

Understanding IRS Private Letter Ruling 202504006: Crucial Takeaways for Tax Planning

Gray Reed on

The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more

Eversheds Sutherland (US) LLP

A fickle friend: Released on the same day, IRS rulings grant and deny 9100 relief

On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more

Freeman Law

S-Corporations | Involuntary Termination of the S-Election

Freeman Law on

Private Letter Ruling 202302004, 01/13/2023, IRC Sec. 1362 - Summary: Entity “A” (“A”) was incorporated as a limited liability company under state law and thus was initially treated as a partnership for federal income tax...more

Freeman Law

Adverse Rulings from the IRS Exempt Organizations Division. How Can Your Organization Learn from Others’ Mistakes?

Freeman Law on

On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more

Cadwalader, Wickersham & Taft LLP

Revenue Adjusted Lease Payments Are Not REIT Qualifying Income

On February 4, 2022, the IRS released a private letter ruling revoking its prior approval of certain lease payments as “rents from real property” for purposes of the REIT income tests....more

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

Jones Day on

On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Orrick, Herrington & Sutcliffe LLP

New IRS Ruling on Port and Airport Leases

In a private letter ruling (PLR 201918008) publicly released earlier this week, the IRS addressed the statutory safe harbor relating to the allowable term for leases of port and airport facilities financed with tax-exempt...more

Stinson LLP

Recent IRS Ruling Creates (Interest)ing Tax Conundrum for Sports Teams Utilizing Personal Seat Licenses

Stinson LLP on

On June 2, 2017, the Internal Revenue Service (IRS) held in a private letter ruling that proceeds used to a fund portion of the new stadium for the Los Angeles Rams franchise of the National Football League (NFL) and received...more

Stinson LLP

Recent IRS Ruling Creates (Interest)ing Tax Conundrum for Sports Teams Utilizing Personal Seat Licenses

Stinson LLP on

On June 2, 2017, the Internal Revenue Service (IRS) held in a private letter ruling that proceeds used to a fund portion of the new stadium for the Los Angeles Rams franchise of the National Football League (NFL) and received...more

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