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No Ruling, No Problem?

How practitioners and fiduciaries should handle topics on which the IRS won’t issue PLRs

The Internal Revenue Service, on a periodic basis, issues revenue procedures that provide a list of issues on which the IRS won’t issue private letter rulings or determination letters. Estate/tax planning professionals colloquially refer to this ever-evolving list as the “no-ruling list.” Perhaps unsurprisingly, when new tax issues are added to the no-ruling list, especially for popular estate planning and trust administration techniques, it can sometimes cause a significant amount of


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