No PLRs Forthcoming on Certain Basis Adjustments in Grantor Trusts

No PLRs Forthcoming on Certain Basis Adjustments in Grantor Trusts

IRS won’t issue private letter rulings on this matter until it resolves the issue through revenue procedures or regulations

In Revenue Procedure 2015-37 (released June 15, 2015), the Internal Revenue Service advised that, until it resolves the issue (through publishing a revenue ruling, procedure or regulation), it wouldn’t issue private letter rulings or determinations on whether assets in a grantor trust receive an Internal Revenue Code Section 1014 basis adjustment at the death of the trust’s deemed owner for income tax purposes, when those assets aren’t includible in the owner’s gross estate under Chapter 11, Subtitle B of the IRC.  Rev. Proc. 2015-37 is applicable to all requests the IRS receives after June 15, 2015.

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