IRS Written Determinations

Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.

40,104 determinations and counting · Newest release October 9, 2026
40,104 determinations

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DET

Art study-abroad grant procedures approved

A private foundation proposed one-time grants for undergraduate and graduate art students participating in a university study-abroad program. The grants would cover program fees, group travel,…

202002017·January 10, 2020
Approved
CCA

Later ownership changes do not alter an earlier tax matters partner designation

Chief Counsel addressed whether later changes in a person's ownership or management status affect that person's role as tax matters partner for an earlier audit year. The advice treats a partnership…

202002015·January 10, 2020
Advice
CCA

Qualified disaster losses use a $500 floor and no AGI threshold

Chief Counsel explained the special deduction limits for qualified disaster-related personal casualty losses. Instead of the ordinary $100 floor for each casualty under section 165(h)(1), a…

202002014·January 10, 2020
Advice
CCA

TCJA section 451 changes do not alter cash-method income rules

Chief Counsel advised that the Tax Cuts and Jobs Act changes to section 451 do not alter the constructive-receipt and prepaid-income rules for cash-method taxpayers. New sections 451(b) and 451(c)…

202002013·January 10, 2020
Advice
PLR

Affiliated hotel manager can remain an eligible independent contractor

A hotel REIT asked whether a hotel manager would remain an eligible independent contractor after being acquired by a company affiliated with the REIT's investment advisor. The advisor also provided…

202002012·January 10, 2020
Approved
CCA

Constructive denial clause does not violate conservation-easement perpetuity rules

Chief Counsel considered a conservation-easement provision requiring the easement holder's express approval for certain land uses. Under the provision, the holder's failure to answer a sufficiently…

202002011·January 10, 2020
Advice
TAM

Standard flash game income does not qualify for the bingo exception

A tax-exempt charity raised money through a game called standard flash, in which players opened pull-tab cards that could be instant winners, instant losers, or cards allowing later number-matching…

202002010·January 10, 2020
Advice
PLR

Affiliated luxury-hotel manager can remain an eligible independent contractor

A luxury-hotel REIT asked whether a hotel manager would remain an eligible independent contractor after being acquired by a company affiliated with the REIT's investment advisor. The advisor also…

202002009·January 10, 2020
Approved
PLR

Taxpayer gets 60 days to file omitted success-fee safe-harbor election

A taxpayer acquired a company and used the Rev. Proc. 2011-29 safe harbor to deduct 70 percent of its success-based transaction fees and capitalize the other 30 percent. Its timely filed return…

202002008·January 10, 2020
Approved
PLR

Estate gets 120 days to make a late portability election

An estate that was not otherwise required to file an estate tax return missed the deadline to elect portability of the deceased spouse's unused estate and gift tax exclusion. Based on the submitted…

202002007·January 10, 2020
Approved
PLR

Consolidated group gets 60 days to waive its loss carryback period

A consolidated corporate group intended to waive the entire carryback period for a consolidated net operating loss, and its returns consistently reflected that intent. A qualified tax professional…

202002006·January 10, 2020
Approved
PLR

Parties get extra time for a section 336(e) asset-sale election

A disregarded buyer acquired all the stock of an S corporation, and the parties intended to treat the transaction as an asset sale under section 336(e). They missed the deadline to execute the…

202002005·January 10, 2020
Approved
PLR

S corporation gets extra time to file its section 336(e) election statement

A buyer acquired more than 80 percent of an S corporation's stock, and the sellers and target timely signed an agreement to elect asset-sale treatment under section 336(e). The target's return and…

202002004·January 10, 2020
Approved
PLR

Foreign entity gets 120 days for a late corporate-classification election

A foreign eligible entity had filed an erroneous election to be treated as a partnership and sought to elect corporate tax status effective on the same redacted date. The entity represented that it…

202002003·January 10, 2020
Approved
PLR

Foreign entity gets 120 days for a late disregarded-entity election

A single-owner foreign eligible entity was classified by default as a corporation because its owner had limited liability. During a reorganization, the entity transferred its assets and liabilities…

202002002·January 10, 2020
Approved
PLR

Estate gets 120 days to make a late portability election

An estate that was not otherwise required to file an estate tax return missed the deadline to elect portability of the deceased spouse's unused estate and gift tax exclusion. Based on the submitted…

202002001·January 10, 2020
Approved
PLR

IRS approves an automatic extension for pension-plan amortization periods

A multiemployer pension plan requested an automatic extension of the periods for amortizing specified unfunded liabilities. The IRS approved the request for the redacted eligible charge bases and a…

202001028·January 3, 2020
Approved
DET

Title-holding company denied exemption because its income went to a nonexempt parent

A corporation held commercial real estate, collected rent from unrelated tenants, and distributed the net income to its sole member. That member was disregarded to a foreign organization that the…

202001027·January 3, 2020
Denied
DET

Visual-artist grant procedures receive advance approval

A private foundation proposed annual grants for emerging and mid-career visual artists in a particular state to create new work and improve their skills. Two panels of visual-arts professionals…

202001026·January 3, 2020
Approved
DET

Inactive private foundation loses section 501(c)(3) status

A private foundation reported no income or expenses on its annual returns, made no charitable contributions, and never carried out its planned scholarships, small-business assistance, or grants to…

202001025·January 3, 2020
Revocation
DET

Organization loses exemption after failing to provide audit information

A charitable organization had been recognized as exempt for a proposed summer camp serving abused, neglected, and abandoned teenagers. The IRS selected it for audit and repeatedly sought financial…

202001024·January 3, 2020
Revocation
DET

Veterans charity revoked for repeated excess-benefit transactions

A veterans charity operated rooming houses and provided transportation to medical appointments, but its president and another officer were domestic partners who controlled its bank accounts without…

202001023·January 3, 2020
Revocation
DET

Ministry loses exemption after its president used funds for personal expenses

A ministry conducted life coaching, prison ministry, athletic coaching, Bible study, and a daily fellowship call. Its founder and president had sole control of its only checking account, and the…

202001022·January 3, 2020
Revocation
DET

Organization loses exemption after failing to answer audit requests

An organization recognized under section 501(c)(3) was selected for an audit of a Form 990-N year and had not filed a Form 990-series return for another year identified in the report. The IRS sent…

202001021·January 3, 2020
Revocation
DET

Animal sanctuary foundation loses exemption after repeated failed audit contacts

The IRS revoked a foundation's section 501(c)(3) exemption after it could not verify that the organization continued to operate for exempt purposes. The foundation had described animal sanctuary,…

202001020·January 3, 2020
Revocation
DET

Exemption revoked because organizing documents failed the organizational test

The IRS revoked an organization's section 501(c)(3) exemption retroactively to its original effective date. The organization had used Form 1023-EZ and attested that its organizing document limited…

202001019·January 3, 2020
Revocation
DET

Motorcycle-event organization loses exemption for private benefit and nonexempt activity

The IRS revoked a motorcycle-event organization's section 501(c)(3) exemption after finding that it operated primarily for social activity and private benefit rather than charity. The organization…

202001018·January 3, 2020
Revocation
PLR

Taxpayer receives 60-day extension to complete accounting-method filing

A corporate taxpayer requested extra time to complete the procedural filing for an automatic accounting-method change. It had timely attached Form 3115 to its return to switch a subcontractor…

202001017·January 3, 2020
Approved
PLR

FCC spectrum sales qualify as made under threat of involuntary conversion

A television broadcaster asked whether a series of asset sales occurred under a threat of involuntary conversion for section 1033 purposes. The FCC's spectrum program offered broadcasters an…

202001016·January 3, 2020
Approved
PLR

Trust receives 120-day extension for charitable-contribution election

A trust made charitable contributions during one tax year and intended to elect under section 642(c) to treat them as paid in the preceding year. Its tax adviser inadvertently failed to file the…

202001015·January 3, 2020
Approved
PLR

Trust receives 120-day extension for charitable-contribution election

A trust made charitable contributions during one tax year and intended to elect under section 642(c) to treat them as paid in the preceding year. Its tax adviser inadvertently failed to file the…

202001014·January 3, 2020
Approved
PLR

Trust receives 120-day extension for charitable-contribution election

A trust made charitable contributions during one tax year and intended to elect under section 642(c) to treat them as paid in the preceding year. Its tax adviser inadvertently failed to file the…

202001013·January 3, 2020
Approved
PLR

Estate receives 120-day extension to make QTIP election

A decedent's revocable trust created a marital trust that paid income to the surviving spouse and held only assets intended to qualify for the estate-tax marital deduction. The estate's return…

202001012·January 3, 2020
Approved
PLR

REIT receives 90-day extension for taxable-subsidiary election

A real estate investment trust and a subsidiary intended to elect taxable REIT subsidiary status effective from the subsidiary's formation. Their outside law firm believed the accounting firm would…

202001011·January 3, 2020
Approved
PLR

Tax-exempt controlled corporation receives late section 168 election relief

A corporation wholly owned by a tax-exempt organization was a limited partner in a partnership formed to operate low-income housing. The partnership agreement required the corporation to elect under…

202001010·January 3, 2020
Approved
PLR

Tax-exempt controlled corporation receives late section 168 election relief

A corporation wholly owned by a tax-exempt organization was the general partner of a partnership formed to operate low-income housing. The partnership agreement required the corporation to elect…

202001009·January 3, 2020
Approved
PLR

Pension plan for church-associated nonprofit qualifies as a church plan

A religiously affiliated nonprofit serving people with developmental disabilities asked whether its defined benefit pension plan qualified as a church plan under section 414(e). The nonprofit was…

202001008·January 3, 2020
Approved
PLR

Foreign entity receives 120-day extension for corporate classification election

A foreign eligible entity failed to timely file Form 8832 to be treated as an association taxable as a corporation from its requested effective date. It represented that it acted reasonably and in…

202001007·January 3, 2020
Approved
PLR

LLC receives late corporate-classification and S corporation election relief

A domestic limited liability company intended from formation to be classified as an association taxable as a corporation and to elect S corporation status. It inadvertently failed to timely file…

202001006·January 3, 2020
Approved
PLR

LLC receives late corporate-classification and S corporation election relief

A multi-member limited liability company intended from formation to elect corporate classification and S corporation status rather than use its default partnership classification. It inadvertently…

202001005·January 3, 2020
Approved
PLR

Corporation receives inadvertent invalid S election relief

A corporation's operating agreement created a second class of stock, making its S corporation election invalid. After discovering the problem, the corporation adopted a new operating agreement that…

202001004·January 3, 2020
Approved
PLR

Donor receives 120-day extension to elect out of automatic GST allocation

A donor and spouse created four irrevocable trusts primarily for their grandchildren, and the donor later transferred the same redacted amount to each trust. The donor did not intend to allocate…

202001003·January 3, 2020
Approved
PLR

Donor receives 120-day extension to elect out of automatic GST allocation

A donor and spouse created four irrevocable trusts primarily for their grandchildren, and the donor later transferred the same redacted amount to each trust. The donor did not intend to allocate…

202001002·January 3, 2020
Approved
PLR

Corporation receives relief for missing consent and ineligible shareholder

A corporation's S election was invalid because the spouse of a shareholder, who held a community-property interest, did not consent on Form 2553. The corporation's stock ledger later also showed…

202001001·January 3, 2020
Approved
DET

Scientific-research travel and collaboration grant procedures approved

A private foundation sought advance approval for grants supporting individuals involved in a scientific research initiative. The grants would fund study, research, writing, lecturing, publication,…

201952010·December 27, 2019
Approved
DET

Large cash contribution qualifies as an unusual grant

A publicly supported charity promoting a sport sought advance recognition that a large cash contribution would be an unusual grant. The charity served youth, veterans, wheelchair participants, and…

201952009·December 27, 2019
Approved
PLR

Foreign company receives 120-day extension for partnership classification election

A foreign eligible entity with multiple owners had a default classification as an association taxable as a corporation. It intended to elect partnership treatment but relied on a tax professional…

201952008·December 27, 2019
Approved
PLR

Foreign company receives 120-day extension for partnership classification election

A foreign eligible entity with multiple owners had a default classification as an association taxable as a corporation. It intended to elect partnership treatment but relied on a tax professional…

201952007·December 27, 2019
Approved
PLR

Tax-exempt controlled corporation receives late section 168 election relief

A corporation wholly owned by a tax-exempt organization was a limited partner in a partnership formed to operate low-income housing. The partnership agreement required the corporation to elect under…

201952006·December 27, 2019
Approved
PLR

Tax-exempt controlled corporation receives late section 168 election relief

A corporation wholly owned by a tax-exempt organization was the general partner of a partnership formed to operate low-income housing. The partnership agreement required the corporation to elect…

201952005·December 27, 2019
Approved
PLR

Partnership may aggregate adjacent nonoperating mineral interests

A partnership held mineral royalty interests across multiple tracts at six properties and asked to aggregate the interests at each property for federal tax purposes. The partnership did not bear…

201952004·December 27, 2019
Approved
PLR

REIT receives 90-day extension for taxable-subsidiary election

A real estate investment trust and a subsidiary intended the subsidiary to be a taxable REIT subsidiary from its formation. An outside firm recommended filing Forms 8832 and 8875 but believed the…

201952003·December 27, 2019
Approved
PLR

Foreign entity may change classification within the 60-month limit

A foreign eligible entity had changed from its default corporate classification to disregarded-entity status. It later underwent a change in ownership of more than 50 percent and wanted to elect…

201952002·December 27, 2019
Approved
PLR

S corporation receives 120-day extension for QSub election

An S corporation purchased all of the stock of another S corporation and intended to treat the acquired company as a qualified subchapter S subsidiary. It failed to timely file Form 8869 for the…

201952001·December 27, 2019
Approved
DET

Soccer referee placement service denied section 501(c)(3) exemption

An organization recruited, trained, mentored, scheduled, and paid independent soccer referees for local leagues under negotiated contracts. Its revenue came from league and association fees, and…

201951015·December 20, 2019
Denied
DET

Industrial park association denied section 501(c)(4) exemption

An association formed to maintain and improve the common areas and shared facilities of a commercial and industrial park sought exemption under section 501(c)(4). Membership was limited to lot…

201951014·December 20, 2019
Denied
DET

Advocacy group denied exemption after failing to detail political activity

An advocacy organization proposed educating voters, facilitating dialogue, identifying common ground, influencing elected officials, and supporting or opposing officials based on their response. The…

201951013·December 20, 2019
Denied
DET

Benefit and social organization denied fraternal-society exemption

An organization provided sick and death benefits to active members, social activities to members, and event-facility rentals. It first sought social-club exemption and then changed its request to…

201951012·December 20, 2019
Denied
DET

Baseball umpire placement organization denied exemption

A membership organization assigned baseball umpires to games, collected their fees and scheduling fees, and paid the member umpires as independent contractors. It sought exemption under sections…

201951011·December 20, 2019
Denied
DET

Business referral network denied business-league exemption

A networking chapter admitted only one member from each professional classification, held weekly meetings, and encouraged members to exchange referrals and promote their individual businesses. It…

201951010·December 20, 2019
Denied

What these documents are

  • Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
  • Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
  • Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
  • Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
  • Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.