IRS Private Letter Ruling Representation

When structuring a planned gift or considering other tax strategies, a review of tax code, regulations, pronouncements, and case law may not produce a clear answer to federal tax issues. When this happens, a private letter ruling from the IRS can confirm in advance the tax consequences of a particular charitable gift or other transaction.

At Keebler & Associates, LLP we use our in-depth and technical knowledge of current tax law and regulations to help our clients assess if a Private Letter Ruling (PLR) is needed. If so, we assist our clients in the process from drafting the Private Letter Ruling to representing clients before the National Office of the Internal Revenue Service (IRS). We have also prepared and submitted exemption requests to the Department of Labor asking for a determination regarding prohibited transactions.

To date, Bob Keebler has drafted over 200 favorable IRS private letter ruling requests including several key rulings of “first impression”. He has assisted clients with the following types of rulings:

  • The qualification of a trust as a designated beneficiary of retirement plans
  • The determination of the applicable life expectancy for post-mortem required minimum distributions
  • Waivers of the 60-day IRA rollover period
  • Late recharacterizations of Roth conversions
  • Late generation skipping transfer tax exemption allocations
  • Modifications of series of equal periodic payments
  • Spousal rollovers of a retirement plan when the account was payable through a trust or estate
  • Contribution of a lump sum distribution containing net unrealized appreciation to a charitable trust
  • Planning techniques involving qualified disclaimers
  • Extension to make a Section 754 election involving the adjustment to basis of partnership property
  • Relief for late S Corporation election
  • Relief for S Corporation stock transferred to a Charitable Remainder Trust
  • Relief for a late estate tax exemption portability election

Family Wealth Transfer Planning Retirement Distribution Planning IRS Private Letter Ruling Representation