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 1105012: IRS approves fund investments inside variable annuity contracts
A life insurance company proposed allowing the funds supporting certain variable annuity contracts to invest in publicly available mutual funds and in funds available only to related managed…
PLR 1105008: IRS approves a cooperative's liquidation-period patronage distribution
A farmers' cooperative stopped operating its auction business after market and regulatory changes reduced the need for its facilities. It kept the facilities while considering whether they might…
PLR 1105005: IRS approves tax treatment of a guaranteed withdrawal annuity certificate
A life insurance company planned to issue a certificate linked to selected assets in a managed account. The certificate would allow withdrawals and provide a guaranteed minimum lifetime benefit if…
CCA 1104031: Settling a variable forward with borrowed shares triggers gain
Chief Counsel advised that settling prepaid variable forward contracts with borrowed shares did not keep the forward contracts open for tax purposes. The forward contracts were closed when the…
CCA 1103043: Counsel addresses the commercial revitalization deduction after a proposed extension
Chief Counsel advised that it was premature to decide how the IRS would treat allocations of commercial revitalization expenditures for 2010. At the time, proposed legislation would extend…
PLR 1103007: Gain from selling a food-processing business is patronage-source income for the cooperative
A tax-exempt farmers cooperative that marketed crops for its members sold an interest in a food-processing business that had provided a market for those crops. The cooperative asked whether the…
PLR 1103001: REIT may make a consent dividend in connection with its liquidation
A real estate investment trust asked whether it could make a consent dividend in the year it completely liquidated, with the amount based on taxable income including gain under section 336 and the…
Counsel discusses mitigation and TEFRA settlement authority
Chief Counsel attorneys answered questions about mitigation provisions, TEFRA partnerships, and settlement authority. The advice states that mitigation can apply to both TEFRA and non-TEFRA…
PLR 1102027: IRS treats proposed compressed natural gas sales as bulk sales
An independent energy company planned to sell compressed natural gas to commercial users and government transportation operations through fueling stations that would not be open to the general…
CCA 1101010: A totalization agreement can make self-employment tax apply to some nonresident aliens
An IRS matter asked about a visa category and whether a nonresident alien owes self-employment tax. The Office of Chief Counsel advised that nonresident aliens generally do not owe SECA tax, but an…
CCA 1052004: Duty of consistency may bar repeated deductions by a related settlement fund
Chief Counsel Advice considers whether the Service may prevent a receiver from claiming deductions on a qualified settlement fund's return when the same expenses were previously deducted on a…
PLR 1051018: Taxpayer granted more time to make an RRSP election
A Canadian citizen who became a United States resident did not know that a Form 8891 election was needed to defer U.S. tax on income accrued in Canadian RRSP accounts. The taxpayer asked for more…
PLR 1050027: Grain payments treated as per-unit retain allocations paid in money
The IRS ruled for a farmers’ cooperative that made payments to members for grain marketed through the cooperative. It concluded that the payments were per-unit retain allocations paid in money under…
PLR 1049007: Cooperative grower payments qualify as per-unit retain allocations
This ruling addresses a farmers' cooperative that processes and markets members' and nonmembers' crops. The IRS concluded that the cooperative's cash grower payments, including initial, interim,…
PLR 1049004: Taxpayers receive more time to make consent dividend elections
A corporate group asked for more time to make consent dividend elections after discovering that a subsidiary had been a personal holding company for several years. The IRS concluded that the…
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.