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 1204004: 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…
PLR 1204003: 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…
PLR 1204002: 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…
PLR 1204001: 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…
CCA 1203017: Advice favors installment-method basis calculation
Chief Counsel advice addressed how to calculate gain attributable to an installment sale. The advice recommends using the installment method under IRC section 453(c), including the gross profits…
PLR 1203003: Power-purchase agreement right is a capital asset
A taxpayer received a power-purchase agreement right through a corporate reorganization and later assigned that right to a buyer. The IRS determined that the right had an indeterminable useful life…
CCA 1202029: CCA addresses property acquired from a decedent
Chief Counsel advice briefly addressed which assets are treated as “acquired from the decedent” for purposes of IRC section 1022(e). The advice pointed to Revenue Procedure 2011-41 as the relevant…
PLR 1201013: IRS permits a retroactive qualified electing fund election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer had relied on tax professionals who did not…
PLR 1152013: IRS allows a retroactive QEF election for a PFIC investment
The IRS granted a taxpayer consent to make a retroactive qualified electing fund (QEF) election for an investment in a foreign corporation treated as a passive foreign investment company (PFIC). The…
PLR 1152007: IRS grants more time for a PFIC mark-to-market election
The IRS granted two regulated investment funds an additional 60 days to make an IRC § 1296 mark-to-market election for shares of a passive foreign investment company. The funds relied on…
Bond rate-period change is not a significant modification
The IRS ruled that a taxpayer’s conversion of two build America bonds to a new term-rate period, with a new interest rate set under the bond terms, would not be a deemed exchange under section 1001.…
IRS approves tax treatment for annuity termination and partnership-interest sale
The IRS approved the requested tax treatment for two trusts that planned to transfer partnership interests to a buyer in exchange for terminating life annuity contracts and receiving cash. The…
CCA 1147024: IRS explains the federal tax treatment of transferable Massachusetts tax credits
Chief Counsel advice addresses the federal tax treatment of several transferable Massachusetts state tax credits. The advice concludes that selling a credit is a taxable event, that the original…
PLR 1147023: IRS permits a retroactive qualified electing fund election
An individual asked the IRS for consent to make a retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer's CPA knew about the investment…
CCA 1144023: Annual fishing-rights transfers produce ordinary income
Chief Counsel considered annual transfers of fishing allocation rights from a taxpayer to a related transferee. The taxpayer retained future rights, including the catch history that could support…
PLR 1144005: IRS says amended installment notes are not disposed of
A shareholder planned to modify promissory notes and stock purchase agreements after an economic downturn reduced the value of the shares sold to employee purchasers. The proposed changes reduced…
TAM 1142020: Restructured commodity call options remained options and hedges
The IRS analyzed a taxpayer's written call options on a commodity after the contracts were restructured. It concluded that the contracts remained options, so losses from closing them were capital…
PLR 1142019: Late mark-to-market election relief granted for PFIC stock
A domestic fund indirectly held passive foreign investment company stock through a foreign partnership. Its accountant prepared the section 1296 mark-to-market election for the foreign partnership…
PLR 1142018: Late mark-to-market election relief granted for PFIC stock
A domestic fund indirectly held passive foreign investment company stock through a foreign partnership. Its accountant prepared the section 1296 mark-to-market election for the foreign partnership…
PLR 1142017: Late mark-to-market election relief granted for PFIC stock
A domestic fund indirectly held passive foreign investment company stock through a foreign partnership. Its accountant prepared the section 1296 mark-to-market election for the foreign partnership…
PLR 1142015: Retroactive QEF election permitted for PFIC investment
A married couple held an investment in a passive foreign investment company through trusts. Their tax adviser did not identify the investment as a PFIC or advise them about the qualified electing…
PLR 1142014: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a married couple's retroactive qualified electing fund (QEF) election for an investment in a passive foreign investment company. The taxpayers said their tax adviser did not…
PLR 1142013: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a married couple's retroactive qualified electing fund (QEF) election for an investment in a passive foreign investment company. The taxpayers said their tax adviser did not…
PLR 1142012: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a married couple's retroactive qualified electing fund (QEF) election for an investment in a passive foreign investment company. The taxpayers said their tax adviser did not…
PLR 1141016: IRS grants more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for more time to make a mark-to-market election for passive foreign investment company stock it held indirectly through a foreign fund. The election form was…
PLR 1141015: IRS grants more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for more time to make a mark-to-market election for passive foreign investment company stock it held indirectly through a foreign fund. The election form was…
PLR 1141014: IRS grants more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for more time to make a mark-to-market election for passive foreign investment company stock it held indirectly through a foreign fund. The election form was…
PLR 1140020: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1140019: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1140018: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1139003: IRS approved mortgage-interest subsidies for servicemembers and their reporting treatment
The IRS considered a mortgage servicer group's plan to subsidize interest for servicemembers covered by the Servicemembers' Civil Relief Act. The subsidy would reduce the servicemember's effective…
PLR 1138026: 60-day extension to make a PFIC mark-to-market election
The IRS granted a domestic fund 60 more days to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company. The election form had mistakenly been attached to…
PLR 1138025: 60-day extension to make a PFIC mark-to-market election
The IRS granted a domestic fund 60 more days to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company. The election form had mistakenly been attached to…
PLR 1138024: 60-day extension to make a PFIC mark-to-market election
The IRS granted a domestic fund 60 more days to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company. The election form had mistakenly been attached to…
PLR 1138023: IRS grants extra time to make a PFIC mark-to-market election
A domestic fund indirectly held stock of a passive foreign investment company through a foreign partnership. The fund's tax adviser prepared the mark-to-market election under IRC § 1296, but…
PLR 1138018: IRS permits a retroactive QEF election for an indirect PFIC investment
A partnership-owned shareholder indirectly invested in a foreign company that became a passive foreign investment company after earning interest income. The shareholder did not make a qualified…
PLR 1138017: IRS permits a retroactive QEF election after an unintended PFIC classification
A shareholder indirectly invested in a foreign company that unexpectedly became a passive foreign investment company after interest income arose on deposited share capital. The shareholder's tax…
PLR 1137007: IRS grants more time to make a mark-to-market election for PFIC stock
A domestic fund indirectly held stock of a passive foreign investment company through a foreign fund. The fund's tax advisor prepared the section 1296 mark-to-market election for the wrong…
PLR 1137006: IRS grants more time to make a mark-to-market election for PFIC stock
A domestic fund indirectly held stock of a passive foreign investment company through a foreign fund. Its tax advisor prepared the section 1296 mark-to-market election for the wrong partnership,…
PLR 1136016: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136015: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136014: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136013: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136012: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136011: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1134017: Transfer of trust assets preserves GST status and avoids gift tax and gain
A taxpayer asked whether a special trustee could move assets from one family trust into a new trust for the same family beneficiary and descendants. The IRS ruled that the receiving trust would keep…
PLR 1131019: IRS allowed a retroactive qualified electing fund election for PFIC shares
A domestic partnership asked to make a retroactive qualified electing fund election for shares in a foreign corporation that it later learned might be a passive foreign investment company. The…
PLR 1131018: IRS allowed a retroactive qualified electing fund election for PFIC shares
A domestic partnership asked to make a retroactive qualified electing fund election for shares in a foreign corporation that it later learned might be a passive foreign investment company. The…
PLR 1131014: IRS approved dividing an irrevocable trust into separate beneficiary subtrusts
A trustee proposed dividing an irrevocable trust created before September 25, 1985 into separate subtrusts, one for each of the grantor's three children and their descendants. The IRS concluded that…
PLR 1129021: Trust consolidation preserves GST exemption and tax attributes
Two irrevocable trusts created before September 26, 1985, had substantially identical terms and beneficiaries. A state court authorized their consolidation into one trust without changing the…
PLR 1129015: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, had not been divided as originally planned and was being administered for two beneficiaries. The trustees and beneficiaries proposed a nonjudicial…
PLR 1129014: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, was held for a beneficiary and later generations. The trustees and beneficiaries proposed a nonjudicial agreement to clarify investment authority,…
PLR 1129013: Trust reformation preserves tax treatment and GST exemption
A family trust created before September 26, 1985, had not been divided as originally planned and was being administered for two beneficiaries. The trustees and beneficiaries proposed a nonjudicial…
PLR 1128018: Consolidating two pre-1985 trusts preserved GST exemption and tax basis
The IRS considered a proposal to combine two substantially identical irrevocable trusts created before September 26, 1985. The trusts would be consolidated without changing the beneficiaries' income…
PLR 1128015: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128014: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128013: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128012: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128011: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1126011: Settlement trust qualified for tax treatment and related deductions
A publicly traded corporation and related parties planned to resolve disputed tort and contract claims through a court-supervised trust. The IRS ruled that the trust would qualify as a qualified…
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.