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.
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.
WPS Resources had previously received two separate private letter rulings
from the IRS in which, among other things, the IRS concluded that the synthetic fuel produced at our facility qualifies for Section 29 tax credits.
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.
13) Reporting the differential payments in Box 1 of Form W-2 (without applying payroll taxation) is consistent with the IRS's conclusion in Private Letter Ruling
In April 2003, the IRS instituted a "temporary pause" in issuing private letter rulings
and has not provided any guidance as to when such issuances might resume.
In recent private letter rulings
, the service said that no opinion would be expressed or implied concerning the application of section 7872 for split-dollar arrangements, but if the IRS begins to impute interest it will be their death knell.
Private letter rulings
(PLRs) and technical advice memoranda (TAMs) issued after Oct.
In contrast to the line of Revenue Rulings discussed above, in a recent set of Private Letter Rulings
(PLRs), the IRS has taken a more conservative position regarding professionals (see PLRs 9041030-034, Oct.
The addition of Shepard's Signal indicators gives tax practitioners a quick and easy visual reading of the Revenue rulings, Private Letter Rulings
, Revenue Procedures and case law to help users determine if points of law and rulings are still valid, a feature especially valuable in today's demanding regulatory environment.
According to the revenue procedure, which was released on June 23, 2003, the IRS will continue to issue private letter rulings
concluding that transactions qualify under section 355, but will base those rulings on the taxpayer's representations that the foregoing three core requirements are satisfied.