Private Letter Rulings

Private Letter Rulings are written decisions by the Internal Revenue Service (IRS) in response to a Taxpayer'­s requests for guidance. A Private Letter Ruling binds only the IRS and the requesting Taxpayer. Thus, a Private Ruling may not be cited or relied upon as precedent.

 

Apr 2014 - Private Letter Ruling 201416006 - IRS allows Same Property to be "Parked" for Multiple Potential Like-Kind Exchanges

 

Jan 2013 - Private Letter Ruling 201302009 - IRS Rules on Deed in Lieu of Foreclosure

 

May 2012 - Private Letter Ruling 201220012 - IRS allows exchange of related parties

 

Apr 2012 - Private Letter Ruling 201216007 - IRS Allows related party to receive boot

 

Dec 2010 - Private Letter Ruling 201048025 - IRS allows exchange of related parties

 

Jul 2010 - Private Letter Ruling 201030020 - IRS rules Bank merged with QI not a disqualified party

 

Jul 2010 - Private Letter Ruling 201027036 - IRS allows 1031 exchange of related parties with controlled foreign corporation (CFC)

 

Jun 2010 - Private Letter Ruling 201024036 - Emission credits considered like-kind and allowed in 1031 exchange

 

Nov 2009 - Private Letter Ruling 200649028 - IRS held that a stewardship easement was like kind to a fee interest in real estate

 

Sep 2009 - Private Letter Ruling 200921009 - Partnership Divided During 1033 Replacement Period

 

May 2009 - Private Letter Ruling 200919027 - IRS allows exchange of related parties

 

Apr 2009 - Private Letter Ruling 200912004 - IRS rules that cars and light-duty trucks qualify as like-kind

 

Mar 2009 - Private Letter Ruling 200908005 - IRS ruled that entity change of QI does not invalidate open exchanges

 

Mar 2009 - Private Letter Ruling 200909008 - IRS allows EAT to acquire partnership interest in replacement property

 

Mar 2009 - Private Letter Ruling 200901020 - IRS allows exchange of residential density development rights

 

Feb 2009 - Private Letter Ruling 200901004 - IRS allows non-safe harbor reverse exchange

 

Nov 2008 - Private Letter Ruling 200724007 - IRS rules that a qualified intermediary owned by a disqualified party is not deemed a disqualified party.

 

Nov 2008 - Private Letter Ruling 200803003 - IRS provides clarification on the definition of routine financial services in regards to a disqualified entity

 

Nov 2008 - Private Letter Ruling 200805012 - IRS ruled that development rights were like-kind and could be swapped for a fee interest in property as long as the development rights do not set an expiration date.

 

Nov 2008 - Private Letter Ruling 200807005 - Disregarded entity received all interest in partnership that owns the replacement property qualifies for in a 1031 exchange.

 

Nov 2008 - Private Letter Ruling 200810016 - Related party transaction allowed in 1031 exchange

 

Nov 2008 - Private Letter Ruling 200812012 - Replacement property contributed to new partnership qualifies in a 1031 exchange

 

Nov 2008 - Private Letter Ruling 200813019 - IRS permits taxpayer to revoke inadvertent opt-out from installment method in a failed exchange

 

Nov 2008 - Private Letter Ruling 200820017 - IRS allows related party exchange when parties agree to hold properties for at least two years

 

Nov 2008 - Private Letter Ruling 200820025 - IRS again allows related party exchange when parties agree to hold properties for at least two years

 

Nov 2008 - Private Letter Ruling 200829013 - Provides additional guidance for taxpayers structuring two 50% undivided fractional interests in replacement property of a 1031 exchange.

 

Nov 2008 - Private Letter Ruling 200829023 - The IRS addresses the allocation of gain on boot from a in a 1031 exchange

 

Nov 2008 - Private Letter Ruling 200842019 - IRS approves exchange of leaseholds and personal property

 

Jan 2008 - Private Letter Ruling 200901020 - IRS ruled that residential density development rights under recorded restrictive covenants are of like-kind to other interests in real estate

 

Dec 2006 - Private Letter Ruling 200616005 - Related Parties

 

Dec 2006 - Private Letter Ruling 200718028 - IRS rules that identification requirements met in a reverse exchange when relinquished property is delivered to the qualified intermediary with the 45 identification period.

 

Nov 2006 - Private Letter Ruling 200709036

 

Apr 2006 - Private Letter Ruling 200651030 - Testamentary Trusts

 

Oct 2004 - Private Letter Ruling 20044002 - Related Parties

 

May 2004 - Private Letter Ruling 200521002 - Testamentary Trusts

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