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Nuts & Bolts of Private Letter Rulings
Trusts and Estates Section and Taxation Section - Estate and Gift Tax Division
Private letter rulings (PLRs) are one of many tools that tax and wealth planning professionals can employ to benefit their clients, but many professionals are unaware of the benefits of PLRs or don’t know how to obtain PLRs. This presentation will discuss the most common estate, gift, and generation-skipping transfer tax PLRs, issues on which the IRS will not issue a PLR, guidelines for preparing and submitting a PLR request, and working with the IRS to obtain a PLR.
1 Participatory MCLE Credits
Anna Soliman, Moderator
Anna K. Soliman, Managing Director and Trust Counselat Fiduciary Trust International,is a senior trusts and estates advisor with broad experience in the area of estate planning and trust and estate administration, including preparing and reviewing estate tax returns and gift tax returns, and leading audits against the Internal Revenue Service (IRS). Anna was most recently an attorney in private practice in Los Angeles, where her responsibilities included crafting and preparing complex estate plans and business succession plans for high-net-worth individuals. She also assisted clients in matters ranging from trust administration and probate to IRS audits. Earlier in her career, she worked for the IRS as an estate tax attorney and served as deputy district attorney in the Sacramento County District Attorney’s Office. Anna earned her Master of Laws (LLM) from Chapman University School of Law, her Juris Doctor degree from the University of California Davis School of Law. Anna is on the Executive Committee of the Trust and Estates Section of the California Lawyer’s Association and a Vice-Chair of the Fiduciary Income Tax Section of the American Bar Association.
David Y. Oh
S. Eva Wolf
S. Eva Wolf joined the IRS Office of Associate Chief Counsel (PSI) as a Senior Attorney (Tax) in April 2020, relocating to Washington D.C. from Los Angeles as the world went into lockdown. (She clearly has impeccable timing!) Eva also is the current Co-Chair of Counsel’s LGBTQ+ Cohort Group. Eva’s 15-year legal career has followed an atypical path; she has twice moved between private practice and government practice. Towards the beginning of her legal career, she worked as an Attorney (Estate Tax) in the IRS Estate & Gift Tax division, then returned to private practice where she advanced from associate to partner at Mitchell Silberberg & Knupp LLP, one of the oldest and most respected law firms in Los Angeles. Prior to joining PSI, Eva was a partner at Withers Bergman LLP, an award winning, global law firm. An Arizona native, Eva earned a B.A. in Sociology and a minor in Philosophy from Arizona State University and a J.D. from the University of Arizona. Eva also earned a Tax LL.M. from Loyola Law School, where she now teaches Estate & Gift Tax.
Description
Pages
File Size
CLA - PLRs (2022).pdf
47
1 MB
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S. Eva Wolf joined the IRS Office of Associate Chief Counsel (PSI) as a Senior Attorney (Tax) in April 2020, relocating to Washington D.C. from Los Angeles as the world went into lockdown. (She clearly has impeccable timing!) Eva also is the current Co-Chair of Counsel’s LGBTQ+ Cohort Group. Eva’s 15-year legal career has followed an atypical path; she has twice moved between private practice and government practice. Towards the beginning of her legal career, she worked as an Attorney (Estate Tax) in the IRS Estate & Gift Tax division, then returned to private practice where she advanced from associate to partner at Mitchell Silberberg & Knupp LLP, one of the oldest and most respected law firms in Los Angeles. Prior to joining PSI, Eva was a partner at Withers Bergman LLP, an award winning, global law firm. An Arizona native, Eva earned a B.A. in Sociology and a minor in Philosophy from Arizona State University and a J.D. from the University of Arizona. Eva also earned a Tax LL.M. from Loyola Law School, where she now teaches Estate & Gift Tax.
