ruling

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Related to Private Letter Rulings: Technical Advice Memorandum

Ruling

A judicial or administrative interpretation of a provision of a statute, order, regulation, or ordinance. The judicial determination of matters before the court such as the admissibility of evidence or the granting of a motion, which is an application for an order.

ruling

n. court decision on a case or any legal question.

ruling

noun adjudication, award, command, court's finding, decision, decree, determination, edict, finding, findings of fact and conclusions of law, judgment, judicial determination, judicial proclamaaion, judicial pronouncement, opinion of the court, order, order of the court, pronouncement, resolution, rule, verdict
Associated concepts: judicial ruling, ruling from the bench
See also: absolute, act, adjudication, authority, award, canon, central, code, conclusion, condition, conviction, decree, determination, dictate, directive, documentation, dominant, edict, enactment, essential, finding, finding of guilt, influential, judgment, mandate, master, measure, omnipotent, opinion, order, potent, powerful, predominant, prescription, prevailing, primary, principal, pronouncement, requirement, rubric, sentence, sovereign, verdict
References in periodicals archive ?
Finally, with IRS budget cuts and dwindling personnel hours devoted to private letter rulings, there may be a significant time lag between the submission and receipt of the ruling.
Moreover, the IRS has issued numerous private letter rulings concluding that the activities of quasi-governmental economic development entities constitute "essential governmental functions.
49) Shortly after the doctrine's codification, however, the Service stated that it does not intend to issue guidance regarding the types of transaction to which the Economic Substance Doctrine either applies or does not apply, and that it will not issue private letter rulings or determination letters regarding whether a transaction complies with the doctrine.
Per Private Letter Ruling 201245004, a surviving spouse who, prior to making a disclaimer, received distributions in excess of the deceased's spouse RMD was ruled as having made a qualified disclaimer by the IRS.
Therefore, a foreign shipping company that is trying to determine if its income will be considered incidental to the international operation of ships and thus, qualify for a section 883 exemption may have to rely on private letter rulings that could ultimately be revoked or modified.
IRS officials are asking comments about the appointment powers of trust distribution committee members and ways to create similar trust structures that would achieve the objectives of the transactions described in the private letter rulings.
The process a taxpayer should follow in applying for--and ultimately receiving--a private letter ruling is set out by the IRS each year.
Treasury regulations issued under section 6662 provide that both private letter rulings and GCMs are substantial authority, reversing the position under the old regulations cited by the court.
13) Reporting the differential payments in Box 1 of Form W-2 (without applying payroll taxation) is consistent with the IRS's conclusion in Private Letter Ruling 8315021 (Jan.
2003-48 (IRB 2003-29, 7/21/03) announced a plan to provide more published guidance and fewer private letter rulings (PLRs) under Sec.
In recent private letter rulings, the service said that no opinion would be expressed or implied concerning the application of section 7872 for split-dollar arrangements, but if the IRS begins to impute interest it will be their death knell.
Several proposed and final regulations were issued, a few court cases (including a Supreme Court decision) were decided, and some revenue rulings and a plethora of private letter rulings were released.