ruling

(redirected from Private Letter Rulings)
Also found in: Dictionary, Thesaurus, Legal, Encyclopedia.
Related to Private Letter Rulings: Technical Advice Memorandum

Ruling

An official opinion by the IRS on how it interprets U.S. tax law. The IRS may make a ruling, for example, after seeing taxpayers apply a deduction or credit to an unusual, but still relevant situation. The IRS determines whether or not it will accept the situation, and, afterward, applies the ruling to all comparable situations. It is also called a revenue ruling, a letter ruling, or a private letter ruling.

ruling

References in periodicals archive ?
This is particularly true with respect to an issue that has not been addressed in case law or other binding authority and there are numerous private letter rulings with similar facts and similar results.
Most of the recent guidance in this area comes from revenue rulings and private letter rulings, and the recent set of private letter rulings provides helpful analysis of each element.
In this respect, adjudication, private letter rulings, and licensing all allow for incrementalism and flexibility in line drawing (since these instruments allow for case-by-case decisions), whereas rulemaking, which adopts a single rule in all cases, does not.
Businesses may look to private letter rulings concerning other taxpayers in an attempt to determine their own tax liability, but they may not rely on them as precedent.
In the private letter rulings, IRS officials have concluded that the trusts administered by trust beneficiary committees do not have to pay gift taxes on any distributions because the beneficiary committee members have conflicting interests and do not have general powers of appointment over the trust, officials say.
The receipt of the private letter ruling is one of the conditions to the completion of the Split-Off and the DTV Business Combination, and eliminates a potential termination right in favor of Liberty Media that previously existed under the merger agreement.
Court of Appeals for the 11th Circuit indicated that "taxpayers who have not requested or received private letter rulings from the IRS will not succeed on a claim of discriminatory treatment because other taxpayers have received private letter rulings on the tax consequences of the same activities" (Willard K.
The regulation says private letter rulings and GCMs are not authoritative.
In General Counsel Memorandum 39862, the IRS reviewed three private letter rulings that had approved specific hospital-physician joint ventures involving the sale of part of hospitals' revenue streams to physician participants.
The IRS also has never issued any private letter rulings or other legal memoranda discussing or applying Rev.