There seems to be a bit of confusion about how influential GLAM can be. GLAM, short for "glamorous" and a moniker appropriated to describe a genre of rock musicians and bands from the 1960s, 1970s and 1980s, "glam rockers". Think Roxy Music, David Bowie, KISS, The Sweet and T-Rex. But I digress. Today we are playing IRS Alphabet Soup and for starters, let's explore whether a GLAM can rock your world.
A GLAM or generic legal advice memorandum constitutes internal IRS legal advice by the Office of Chief Counsel to assist IRS service personnel in administering their duties. A GLAM is not binding law and cannot be used or cited as precedent
Source: KPMG May 2022. KPMG International Limited is a multinational professional services networkand is one of the so-called Big Four accounting organizations.
Private Letter Rulings ("PLRs"), Technical Advice Memoranda ("TAMs") and Field Service Advice Memoranda ("FSAs") are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and/or Internal Revenue Service officials.
A technical advice memorandum, or TAM, is:
It is important to note that, pursuant to 26 USC 6110(k)(3), such items cannot be used or cited as precedent. To wit "Unless the Secretary otherwise establishes by regulations, a written determination may not be used or cited as precedent. The preceding sentence shall not apply to change the precedential status (if any) of written determinations with regard to taxes imposed by subtitle D of this title"
Source: IRS.gov
A Rev. Proc,, or revenue procedure, is an official statement of a procedure published in the Bulletin that either affects the rights or duties of taxpayers or other members of the public under the Internal Revenue Code and related statutes, treaties, and regulations or, although not necessarily affecting the rights and duties of the public, should be a matter of public knowledge. – Rev. Proc. 89-14, 1989-8 I.R.B. 20.
Source: IRS.gov
A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts.
Source: IRS. gov May 31, 2022
A regulation is issued by the Internal Revenue Service and Treasury Department to provide guidance for new legislation or to address issues that arise with respect to existing Internal Revenue Code sections. Regulations interpret and give directions on complying with the law. Regulations are published in the Federal Register. Generally, regulations are first published in proposed form in a Notice of Proposed Rulemaking (NPRM). After public input is fully considered through written comments and even a public hearing, a final regulation or a temporary regulation is published as a Treasury Decision (TD), again, in the Federal Register.
But it's the GLAM that seems to hog all the attention.
4structures.com, LLC
The Structured Settlements and Settlement Planning Company
43 Harbor Drive, #309 Stamford, CT 06902 USA
888-325-8640
646-849-1588
New York City (Manhattan, Bronx, Brooklyn, Queens, Staten Island), Westchester(NY), Nassau County (NY) , Suffolk County on Long Island (NY), Albany County (NY), Oswego County (NY), Steuben County (NY), Broome County (NY), Onondaga County (NY), Monroe County (NY), Fairfield County (CT), New Haven County (CT), Hartford County (CT) New London County (CT), Tolland County (CT), Litchfield (CT), Middlesex (CT) , Bergen County (NJ), Middlesex County (NJ), Ocean County (NJ)
Structured Settlement Experts and Settlement Planning Consultants for settlements from claims or lawsuits arising out of Aviation accidents, Medical Malpractice, settlements involving Serious Personal Injury, Wrongful Death, Wrongful Incarceration, Employment, Civil Rights, Discrimination of any type, Auto accidents, Motorcycle accidents, Maritime accidents, Workers' Compensation, Product Liability, Real Estate Liability, Construction Defect claims or lawsuits, Landlord/Tenant,
Property, Attorney Fee Deferrals, Funding Agreements, Structured Installment Sales, Environmental Liability and Commercial Dispute settlements.
Structured settlements and structured settlement brokerage, settlement planning, Sudden Money®, financial transitionist, funding agreements and insurance related services provided by 4structures.com LLC.
Financial Advisory Services provided through Groove Financial Advisors , LLC, and its service partners.
Fiduciary services, including the custody and administration of trusts provided via service partners.
Securities and Insurance Products are NOT Insured by the FDIC, nor by any other Federal or State Government Agency, are NOT a Deposit of and are NOT Guaranteed by a Bank or any Bank Affiliate, and securities MAY lose value.
4structures (USPTO Reg. 4640532) , 4structures.com (USPTO Reg. 4640531) , We Know Structured Settlements (USPTO Reg. 3089738),
Because Certain Sells (USPTO Reg. 6237309) and We Know Structured Sales (USPTO Reg. 3490489), are Registered Trademarks of 4structures.com LLC.
John Darer is a Registered Trademark of John Darer (USPTO Reg. 4674907)
John Darer California insurance license 0761076
4structures.com LLC CA license OF19785 d/b/a 4structures Settlement Insurance Agency