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Revocations and Rejections

Tuesday, October 13, 2015

This week's release of private letter rulings included one revocation, PLR 201541012, sustained on appeal.

PLR 201541003 - Late ESBT Election

Monday, October 12, 2015

In PLR 201541003, the Service granted inadvertent termination relief to an S corporation where the trustee of a testamentary trust failed to make a timely ESBT election to maintain subchapter S status.

PLR 201541011 - Scholarship Exception Ruling

Monday, October 12, 2015

In PLR 201541011, the Service determined a private foundation's grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

Realignment Opens Up Pre-submission Conference Process

Monday, October 12, 2015


A lawyer in the TE/GE function of the Office of Chief Counsel told lawyers representing nonprofit healthcare providers, that an organization reluctant to pay the user fee for a private letter ruling could first ask for a pre-submission conference.

College Endowments Again Under Scrutiny

Friday, October 9, 2015


The Oversight Subcommittee of the House Committee on Ways and Means heard testimony on the relationship between federal tax policy and the rising cost of college education. Much of the discussion centered on endowment spending policies and executive compensation.

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