IRS Issues PLR Confirming Qualified Settlement Fund, Governmental Function Income Exclusion

The IRS has issued a private letter ruling on I.R.C. §§115 and 468B and Treas. Reg. §1.468B confirming Trust qualifies as a qualified settlement fund under Treas. Reg. §1.468B-1(c), may exclude transferred assets from modified gross income under Treas. Reg. §1.468B-2(b)(1), and Trust’s income is excludable from gross income under I.R.C. §115 because Trust performs essential governmental functions with income accruing to states and political subdivisions for public health crisis abatement purposes. [PLR 202624002]

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