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.
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PLR 1237011: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days from the ruling date to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer…
PLR 1237004: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer to defer current…
PLR 1237002: Married taxpayers receive more time to elect Canadian RRSP tax deferral
The IRS granted a married couple 60 days to elect treaty treatment that defers U.S. tax on income accrued in their Canadian registered retirement savings plans, or RRSPs. The couple had moved to the…
100 percent reinsurance reduces the unearned premium reserve
The Technical Advice Memorandum considers whether a nonlife insurance company may maintain an unearned premium reserve for contracts whose insurance risk was fully reinsured. The IRS concludes that…
Separate-account ownership differs by contract type
A life insurance company planned to restructure how it held real estate investments backing pension and non-pension annuity contracts. The IRS concluded that the insurer would remain the federal tax…
IRS approves a cooperative's qualified intermediary and patronage-income treatment
The IRS ruled that a cooperative's disregarded qualified intermediary could provide qualified intermediary services for its shareholders' like-kind exchanges without being treated as a disqualified…
IRS says offsetting currency forwards are not substantially similar to a listed transaction
The IRS ruled that a taxpayer's proposed offsetting foreign-currency forward contracts were not the same as, or substantially similar to, the listed transaction described in Rev. Rul. 2000-12. The…
PLR 1232030: IRS approves privatization transfer of a government insurance fund
A government-established insurance fund planned to transfer its insurance business and subsidiaries to a new mutual insurer as part of a state-law privatization. The new insurer would issue…
PLR 1232025: IRS grants more time to elect treaty deferral for Canadian retirement plans
Two married taxpayers maintained Canadian Registered Retirement Savings Plans after moving to the United States. They had not filed the required Forms 8891 or otherwise elected under Article…
CCA 1231010: U.S.-U.K. treaty advice addresses pension rollovers
Chief Counsel advice considers whether a U.K. resident could transfer funds from a U.S. pension scheme to a U.K. pension scheme without current U.S. tax. The advice concludes that Article 18(1) of…
PLR 1230012: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect a deferral of U.S. income tax on earnings in a Canadian Registered Retirement Savings Plan under the U.S.-Canada Income Tax Treaty and Rev. Proc. 2002-23.…
PLR 1230009: IRS treats a requested life insurance benefit reduction as a new issuance
The IRS ruled that reducing the face amount of certain life insurance contracts at an owner’s request would be treated as an exchange that makes the contracts newly issued for…
PLR 1229008: IRS treats a roadside-assistance provider as an insurance company
The IRS ruled that a roadside-assistance provider qualified as an insurance company taxable under IRC § 831. The provider issued risk-based contracts requiring it to provide assistance after…
IRS approves substitute mortality tables for specified pension plans
The IRS approved a request to use substitute mortality tables for the pension plans in a specified permissive group. The approval applies to the listed bargaining-unit and non-bargaining-unit male…
PLR 1228054: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The extension was granted under IRC § 431(d)(1) after the plan submitted the required…
PLR 1228053: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
PLR 1228052: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
PLR 1228051: IRS approves a pension plan’s annuity settlement window
The IRS approved a pension plan amendment creating a one-time window for certain retirees and beneficiaries to exchange future annuity payments for a qualified annuity option or a lump-sum payment.…
PLR 1228050: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
PLR 1228049: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
IRS advice defers cooperative patronage-dividend deductions under IRC § 267
The Office of Chief Counsel concluded that IRC § 267(a)(2) applies to patronage dividends paid by a cooperative to related domestic patrons, so the cooperative may not deduct the amounts until they…
PLR 1228014: IRS treats a rural telephone cooperative's stock-sale gain as patronage-sourced
A rural telephone cooperative planned to sell stock in a telecommunications service company and use the proceeds for construction projects serving its members. The cooperative had acquired and held…
PLR 1226039: IRS permits late recharacterization of Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize two Roth IRA conversions as traditional IRAs. The couple said they relied on a financial advisor who did not explain that the 2008…
CCA 1226022: Advice says tanning enrollment and freeze fees are taxable
Chief Counsel advice addresses whether enrollment and freeze fees charged by indoor tanning service providers are subject to the 10 percent excise tax under IRC § 5000B. It concludes that both types…
PLR 1226010: IRS grants more time for Canadian RRSP treaty elections
Two married taxpayers asked for more time to elect under Rev. Proc. 2002-23 to defer U.S. income taxation on earnings in Canadian Registered Retirement Savings Plans under Article XVIII(7) of the…
PLR 1225013: IRS denies request concerning an invalid small insurance company election
An insurance company asked the IRS to revoke an election to be taxed only on investment income under IRC § 831(b). The company had not yet issued insurance policies during the short year when it…
CCA finds a public utility eligible for the section 1341 exception
Chief Counsel Advice considers whether a taxpayer that sold a regulated product qualified as a regulated public utility for the public-utility exception to the inventory rule in IRC § 1341(b)(2).…
PLR 1224018: IRS approves captive insurer's pooled reinsurance arrangement
The IRS ruled that a captive insurer's contracts with affiliated businesses, combined with participation in a reinsurance pool of unrelated insurers and insureds, constituted insurance for federal…
PLR 1224015: IRS allows a late Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to make a late election to defer U.S. federal income tax on income accruing in one Canadian Registered Retirement Savings Plan. An accounting firm had filed the…
CCA explains when Appeals may address a future-year item in a closing agreement
Chief Counsel Advice addressed whether Appeals may enter a closing agreement covering a specific item in a future taxable year while that year is under examination. The advice explained that a…
PLR 1222021: IRS grants more time to defer tax on Canadian retirement savings
The IRS granted a U.S. resident 60 days to make an election under Rev. Proc. 2002-23 for deferral of U.S. federal income tax on income accruing in a Canadian Registered Retirement Savings Plan. The…
PLR 1222019: IRS grants more time for two taxpayers to defer Canadian RRSP income
The IRS granted a married couple 60 days to make elections under Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in their Canadian Registered Retirement Savings Plans. The couple had…
Ruling requests about purported Social Security trusts refused
Chief Counsel's advice addresses two nearly identical requests about purported trusts allegedly created when the Social Security Administration issued social security cards. The requesters claimed…
PLR 1220014: Taxpayer receives more time to elect RRSP income deferral
The IRS granted a U.S. citizen more time to elect deferral of U.S. income tax on earnings in a Canadian registered retirement savings plan. The taxpayer had relied on tax preparers who did not…
PLR 1219011: Pooled reinsurance arrangement qualifies as insurance for federal tax purposes
A company asked whether its contracts with an affiliated insured qualified as insurance for federal income tax purposes. The company directly insured the affiliated corporation, ceded a substantial…
PLR 1219010: Pooled reinsurance for related insureds qualifies as insurance for federal tax purposes
A company asked whether its contracts with related insureds qualified as insurance for federal income tax purposes. The company directly insured a partnership and a corporation, ceded premiums and…
PLR 1219009: Pooled reinsurance for a medical partnership qualifies as insurance
A company asked whether its contracts with a medical partnership qualified as insurance for federal income tax purposes. The company directly insured the partnership, ceded premiums and risks to a…
PLR 1219004: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect to defer U.S. income taxation on income accrued in three Canadian Registered Retirement Savings Plans under Revenue Procedure 2002-23 and the U.S.-Canada…
PLR 1219001: Cooperative may treat c-Check payments as per-unit retains for its section 199 deduction
An agricultural cooperative asked whether payments it made to members before the end of its annual pool qualified as per-unit retain allocations paid in money. The cooperative called these payments…
PLR 1216031: REIT distribution qualifies for the dividends paid deduction
A publicly traded real estate investment trust (REIT) issued common and convertible stock while declaring a quarterly distribution. The transaction included a payment intended to adjust for the…
PLR 1216011: IRS treats cooperative payments as per-unit retains for the § 199 deduction
A farmers' cooperative marketed agricultural products for its member associations and their patrons through both consignment sales and direct purchase arrangements. The cooperative asked whether…
CCA 1213025: An electronic signature can have the same effect as a handwritten signature
Chief Counsel Advice addressed whether an electronic signature could be used on a Form 872, which extends the period for assessing tax. It said an electronic signature has the same effect as a…
PLR 1213014: IRS grants extra time for a Canadian RRSP treaty election
The IRS granted a taxpayer 60 days to elect treaty treatment that defers U.S. tax on income accruing but not distributed by a Canadian registered retirement savings plan. The taxpayer became a U.S.…
CCA 1212008: IRS analyzes taxation of green card holders working for the Italian Embassy
The Office of Chief Counsel analyzed whether lawful permanent residents working for the Italian government in the United States could exclude their compensation from United States federal income…
PLR 1210013: Taxpayer receives more time to elect treaty deferral for Canadian RRSP income
The IRS granted a taxpayer an extension of time to make an election under the U.S.-Canada Income Tax Treaty and Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in three Canadian…
PLR 1210009: Taxpayer receives more time to make a Canadian RRSP election
The IRS granted a taxpayer 60 days to make an election under the U.S.-Canada Income Tax Convention and Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in a Canadian registered…
PLR 1210003: Oil and gas subsidiaries retain independent producer status despite retail activities
The IRS ruled that an oil and gas company's producing subsidiaries would continue to qualify as independent producers for percentage depletion purposes under IRC § 613A(c). The ruling covered a…
CCA 1208027: Mitigation provisions do not allow a refund of closed-year AMT
Chief Counsel advised that the mitigation provisions do not allow a taxpayer to recover AMT paid for 2007 when an increased net operating loss from 2006 must be carried forward and the 2007 refund…
PLR 1208025: Corporation is not a personal holding company under constructive ownership rules
The IRS ruled that a publicly traded corporation in a consolidated group was not a personal holding company for five tax years. Applying the constructive ownership rules, the IRS determined that the…
PLR 1208008: IRS confirms cooperative status after an organizational alignment
The IRS ruled that a cooperative serving hospitals would continue to operate on a cooperative basis after an alignment transaction with two related nonprofit organizations. The transaction would…
PLR 1205004: IRS approves multi-class REIT shares with class-specific fees
The IRS ruled that a public non-traded real estate investment trust could issue two new classes of common stock with different distribution and advisory-fee allocations. The class-specific fees…
CCA 1204012: Counsel comments on claimed losses and transaction costs
Chief Counsel provided comments on a rebuttal involving claimed losses and transaction costs. The advice distinguishes the timing rule for loss deductions under IRC § 165 from the separate question…
IRS revokes section 501(c)(3) status of a consumer credit counseling organization
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption. The determination states that the organization did not primarily conduct activities serving…
PLR 1202014: IRS approves consent dividend treatment in a REIT liquidation
The IRS ruled on a proposed complete liquidation of a real estate investment trust that owned a subsidiary holding industrial properties. It concluded that IRC section 1374(d)(7)(B) applied to the…
PLR 1201011: IRS grants 45 days to make consent dividend elections
The IRS granted a limited liability company 45 days to file the forms needed to make consent dividend elections for three taxable years. The taxpayer had been advised that it might be a personal…
PLR 1201010: IRS grants more time for a bank-affiliate disaffiliation election
The IRS granted a bank holding company 90 days to make an election to disaffiliate a failed bank subsidiary from its consolidated tax group. The state banking department had placed the institution…
PLR 1201001: IRS finds no information reporting duty for a pharmacy network manager
The IRS determined that a pharmacy benefit management business did not have an information reporting obligation under IRC § 6050W for its payments to pharmacies. The business gave health plan…
PLR 1152006: IRS treats cooperative member payments as per-unit retains
The IRS ruled that cash payments by an agricultural marketing cooperative to its producer-members are per-unit retain allocations paid in money under IRC § 1382(b)(3). The payments were made under…
Determination 1150033: IRS revoked a charitable organization's tax-exempt status
The IRS revoked a charitable organization's tax-exempt status under section 501(c)(3). The organization did not respond to repeated requests to inspect its books and records. Bank records obtained…
Determination 1149033: IRS revoked a charitable organization's exemption after asset diversion and record failures
The IRS revoked a charitable organization's section 501(c)(3) exemption effective January 1, 20XX. The organization had ceased operations and failed to provide records showing how its charitable…
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.