IRS Alphabet Soup GLAM, TAM, PLR, Rev Ruling, Rev. Proc

John Darer • January 13, 2023

The GLAM Influence Over The Years

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.


What is a GLAM?


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.


What Are PLRs, TAMS and FSAs?


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.


Private Letter Ruling  (PLR)   What is it?


  • A PLR is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's specific set of facts.
  • A PLR is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer's return is filed.
  • A PLR is issued in response to a written request submitted by a taxpayer and is binding on the IRS if the taxpayer fully and accurately described the proposed transaction in the request and carries out the transaction as described.
  • A PLR may not be relied on as precedent by other taxpayers or IRS personnel. PLRs are generally made public after all information has been removed that could identify the taxpayer to whom it was issued.


Technical Advice Memorandum (TAM) |  What is it?


A technical advice memorandum, or TAM, is:


  • Guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding.
  • A request for a TAM generally stems from an examination of a taxpayer's return, a consideration of a taxpayer's claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals.
  • Technical Advice Memoranda are issued only on closed transactions and provide the interpretation of proper application of tax laws, tax treaties, regulations, revenue rulings or other precedents.
  • The advice rendered represents a final determination of the position of the IRS, but only with respect to the specific issue in the specific case in which the advice is issued.
  • Technical Advice Memoranda are generally made public after all information has been removed that could identify the taxpayer whose circumstances triggered a specific memorandum.


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


What is a Rev. Proc.?


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

 

What is a Revenue Ruling?

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


What is a Regulation?


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.



most infomative structured settlement websites
By John Darer August 26, 2025
The 4structures.com website is one of the most comprehensive structured settlement resources, particularly for those who want detailed, expert-level information, according to Google AI
most informative
By John Darer August 22, 2025
Based on Grok's review of prominent sites as of August 2025, 4structures.com (including its associated blog at structuredsettlements.typepad.com) stands out as the most comprehensive. Run by structured settlement expert John Darer, it offers detailed guides, and specialized insights
fountain
By John Darer August 17, 2025
Retained asset accounts for life insurance beneficaries, are temporary accounts that earn interest, give you time to breathe and give you time to figure it out.. Retained asset accounts are pay nterest from the date of death to date of settlement of the claim as a general practice,
knuckles
By John Darer August 16, 2025
How to avoid a "Knuckles Sandwich" when entering into settlement of claims or lawsuits involving taxable damages, or elements of taxable damages. What is the intent of the Payor? What happens if the intent of Payor is not clearly set forth in the settlement agreement?
structured  settlements
By John Darer August 15, 2025
Structured settlement annuity issuers have stood the test of time, which is crucial if you're depending on them to pay you stable income for a long time or the rest of your life or pay your beneficiaries . For Structured settlement annuities . Call John Darer at 888-325-8640
New Y
By John Darer August 14, 2025
While rising yields have narrowed the gap for defendants in New York CPLR 50A and 50B projections, plaintiffs can still " fly inverted" and get plenty of "lift" when negotiating settlements by using savvy settlement experts
baseball caps of many colors
By John Darer July 29, 2025
The cap rate on index linked structured settlement annuities is a limit set by the insurance company on the maximum interest rate that can be credited to the annuity based on the performance of the underlying index that also helps provide the downside prtection..
longevity road
By John Darer July 28, 2025
Do your financial resources give you enough road, or will the road run out before you do? A structured settlement annuity helps mitigate the risk of outliving your savings, no matter how long you live. A structured settlement can inlcude one or more customized payment streams and types.
USAA structured settlements
By John Darer July 16, 2025
USAA Life Insurance Company, an A++ rated insurance company, issues structured settlement annuities with 1%, 2% and 3% COLAs. USAA Life structured settlements are exceptionally compatitive on lifetime benefit payments with long duration certain periods for ages under 35.
MetLife Structured Installment Sales Now Available in New York
By John Darer July 8, 2025
Owners of highly appreciated NY businesses or NY real estate may benefit from a structured installment sale tax deferral program as an alternative to a 1031 exchange. MetLife's structured installment sale program is now available in NY and in all 50 states. Call 888-325-8640 for more info
More Posts