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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 1248009: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a U.S. limited partnership making a retroactive qualified electing fund election for its investment in a foreign corporation that may have been a passive foreign investment…
PLR 1248008: IRS approves changes to an installment obligation
The IRS ruled that changing an installment note's maturity date, obligor, and interest rate would not be treated as a disposition or satisfaction of the installment obligation. The note arose from…
PLR 1248007: IRS approves changes to an installment obligation
The IRS ruled that changing an installment note's maturity date, obligor, and interest rate would not be treated as a disposition or satisfaction of the installment obligation. The note arose from…
PLR 1248006: IRS rules that restructuring an installment note is not a disposition
An individual asked whether changing an installment note from an employee stock ownership plan transaction would trigger current tax recognition. The proposed changes would defer the maturity date,…
PLR 1246022: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted the executrices of an estate 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in…
PLR 1246018: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted an executor 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in 2010. The executor…
PLR 1246017: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted the executors of an estate 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in 2010.…
PLR 1245016: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's personal…
PLR 1245015: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's executrix had…
PLR 1245013: IRS grants a trust more time to make a section 1022 election
The IRS granted the personal representatives of a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The…
PLR 1245012: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The estate's personal representative…
PLR 1245007: IRS approves the division of an irrevocable trust into three separate trusts
The IRS approved a proposed pro rata division of an irrevocable trust created before September 25, 1985, into three separate trusts for three grandchildren and their descendants. The ruling…
PLR 1245006: IRS approves grantor-trust treatment and a post-death basis adjustment
The IRS ruled that a foreign taxpayer would be treated as the owner of an irrevocable trust during the taxpayer's lifetime because the trust's income had to be paid to the taxpayer and its principal…
PLR 1245005: IRS grants extra time to amend a 2010 estate basis allocation
The IRS granted a decedent's personal representative 120 additional days to amend Form 8939 for a 2010 estate. The timely filed form had omitted basis allocations for closely held business…
PLR 1244003: IRS grants more time for a PFIC mark-to-market election
A regulated investment company failed to identify two foreign corporations as passive foreign investment companies and did not make the IRC § 1296 mark-to-market elections for the prior tax year.…
PLR 1243010: Trustee receives more time to make a 2010 basis election
The IRS granted a trustee 120 days to file Form 8939 and make the Section 1022 Election for property acquired from a decedent who died in 2010. The decedent's assets were held in a revocable trust,…
PLR 1243006: IRS approves division of a pre-1985 generation-skipping trust
The IRS approved a proposed division of an irrevocable trust created before September 25, 1985 into four separate trusts for different family lines. It ruled that the divided trusts would retain…
PLR 1243004: Estate gets relief for QTIP and GST elections and trust divisions
The IRS granted an estate 120 more days to make a QTIP election, divide a trust into exempt and non-exempt trusts, make a reverse QTIP election, and allocate the decedent's available GST exemption.…
PLR 1243003: Integrated hotel and apartment units may be one building for depreciation
The IRS ruled that a mixed-use development containing hotel rooms and residential apartments could treat its hotel and apartment condominium units as a single building when determining whether the…
PLR 1242003: IRS approves separate reverse exchanges using one titleholder
The IRS approved a proposed reverse like-kind exchange structure in which a taxpayer and a related affiliate would each enter into separate qualified exchange accommodation arrangements for the same…
IRS advice limits an identified straddle loss to a partner's distributive share
The Office of Chief Counsel considered a U.S. holding company's treatment of identified straddle losses from a foreign partnership. The taxpayer argued that IRC § 1092(d)(4)(C) allowed it to treat…
IRS approves alternative basis recovery for a contingent payment sale
The IRS considered an S corporation's sale of substantially all of its business assets in exchange for a closing payment and contingent earnout and earnup payments. The taxpayer expected to receive…
PLR 1240006: IRS permits late notice of disaster replacement residence
A taxpayer's principal residence was destroyed in a presidentially declared disaster, and the taxpayer later bought and occupied a replacement residence. The taxpayer did not timely notify the IRS…
CCA 1238027: State property classifications do not control federal like-kind exchange treatment
Chief Counsel advised that federal tax law, not state law alone, controls whether exchanged property is of like kind under IRC § 1031. State classifications as real or personal property are…
PLR 1238016: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a personal representative 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases…
PLR 1238012: IRS grants extra time for a 2010 decedent's basis election
The IRS granted the executors of an estate 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis…
PLR 1238011: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a trustee 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases to be allocated…
PLR 1238004: IRS approves a two-trust division and related tax treatment
The IRS approved a proposed division of an irrevocable trust into two separate trusts, one for each of the settlor's children and that child's descendants. The ruling concluded that the division…
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…
PLR 1232021: IRS allows a taxpayer to revoke its election out of installment reporting
A taxpayer sold several properties to related parties and received promissory notes that called for interest payments followed by lump-sum principal payments. The taxpayer's accountant reported the…
PLR 1231003: IRS grants more time to file the 2010 estate basis election
The personal representative of an estate asked for more time to file Form 8939 and make the election under IRC § 1022 for an individual who died in 2010. A qualified tax professional had been…
PLR 1229003: IRS approves stripped-certificate treatment and fixed-investment-trust classification
The IRS approved a structure in which mortgage-backed REMIC Certificates could be deposited into an Exchange Trust and exchanged for multiple classes of Exchange Certificates. The IRS ruled that the…
PLR 1228030: IRS approves a complex corporate separation and spin-off plan
A multinational corporate group asked about a complex restructuring that would separate transferred businesses from retained businesses. The plan included multiple subsidiary liquidations and…
PLR 1228021: IRS permits a retroactive qualified electing fund election
The IRS allowed a regulated investment company to make a retroactive qualified electing fund election for its investment in a passive foreign investment company. The taxpayer had relied on tax…
PLR 1223012: IRS approves a tax-neutral trust division and modification
The IRS approved corrections to two scrivener's errors in an irrevocable trust and a pro rata division of the trust into two successor trusts for separate family lines. The IRS ruled that the…
PLR 1222011: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222010: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222009: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222008: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222007: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222006: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222005: IRS approves a pooled fund's building reacquisition and related tax treatment
The IRS ruled on a tax-exempt organization’s plan to reacquire certain building interests from a pooled income fund in partial satisfaction of the fund’s debt. The IRS concluded that the…
PLR 1222004: IRS treats conservation easement credits as sale proceeds
The IRS concluded that granting a perpetual conservation easement in exchange for mitigation credits is a sale or exchange of property for federal income tax purposes. The taxpayer owned undeveloped…
CCA 1221021: Chief Counsel says section 453A liability is subject to deficiency procedures
Chief Counsel Advice addressed whether the IRS should issue a statutory notice of deficiency to assess and collect a liability under IRC § 453A. The advice distinguished ordinary interest on…
PLR 1221004: IRS includes two payments in the amount realized on a home sale
The IRS ruled that a married couple's amount realized on the sale of their former principal residence included both the payment received from the purchaser and a separate payment received from a…
PLR 1220012: Related parties may complete linked like-kind exchanges
The IRS ruled that a taxpayer could receive like-kind replacement property from related parties through a linked series of deferred exchanges without losing the benefits of IRC § 1031. The related…
PLR 1220009: Foreign subsidiary share repurchase and restructuring qualify for specified tax treatment
The IRS considered a multinational corporate group's plan to repurchase publicly held stock of a foreign subsidiary, reorganize that subsidiary into a newly formed foreign company, and sell the…
PLR 1220006: Consent granted for a retroactive qualified electing fund election
The IRS allowed a limited partnership to make a retroactive qualified electing fund election for an investment in a foreign corporation that appeared to be a passive foreign investment company. The…
PLR 1216010: IRS approves merger of grandfathered trusts without adverse tax effects
The parties proposed merging sixteen subtrusts within four pre-1985 trusts into four surviving trusts, one for each beneficiary, while preserving the original beneficial interests and vesting and…
PLR 1216007: IRS permits a related-party like-kind exchange series under stated conditions
A real estate investment trust asked whether the related-party limits in § 1031(f) would prevent tax deferral for a series of like-kind exchanges involving the taxpayer, a qualified intermediary, an…
TAM 1214021: Put exercises in collar transactions were closed and completed for tax purposes
The IRS considered whether a taxpayer's exercise of put options in four stock collar transactions created closed and completed transactions for federal income tax purposes. The taxpayer had…
PLR 1211009: Rescinded stock sale may be followed by a valid section 338(h)(10) election
The IRS addressed a transaction in which two sellers sold stock of an S corporation, but the parties later learned that their intended section 338(h)(10) election was unavailable for that sale. The…
PLR 1210017: Retroactive qualified electing fund election permitted
The IRS consented to an individual's retroactive qualified electing fund election for shares of a foreign corporation that was later identified as a passive foreign investment company. The taxpayer…
PLR 1208038: Endowment fund units do not create UBTI and are capital assets
The IRS considered a charitable organization that served as trustee and charitable remainder beneficiary of a charitable remainder unitrust. The organization proposed to invest the trust's assets in…
PLR 1208004: IRS approves trust modifications without GST, gift, estate, or income tax consequences
The IRS ruled on proposed changes to an irrevocable trust created before September 25, 1985. The changes would move the trust's administrative situs to another state, add distribution and investment…
PLR 1208003: IRS approves trust modifications without GST, gift, estate, or income tax consequences
The IRS ruled on proposed changes to an irrevocable trust created before September 25, 1985. The changes would move the trust's administrative situs to another state, add distribution and investment…
PLR 1207001: IRS approved proposed administrative changes to an irrevocable family trust
The IRS considered proposed changes to an irrevocable trust created before September 25, 1985, for the benefit of a child and the child's descendants. The changes would move the trust's…
PLR 1206005: Lump-sum divorce settlement receives favorable tax treatment
The IRS ruled on the income, gift, and estate tax treatment of a lump-sum payment from one former spouse to the other under a proposed modification of their divorce settlement. The payment was…
PLR 1205001: IRS approves dividing an irrevocable trust into separate trusts without current tax consequences
The IRS approved a proposed division of an irrevocable trust into two separate trusts, one holding partnership interests in real estate and the other holding marketable securities. The IRS ruled…
PLR 1204005: IRS approves dividing and combining family trusts without current tax consequences
The IRS approved a proposed division of three family trusts into six separate trusts for six children, followed by the merger of related trust shares. The IRS ruled that the transaction would not…
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.