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 1125006: Retroactive qualified electing fund election allowed for a PFIC investment
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer had acquired the investment through a foreign…
PLR 1125005: Retroactive QEF election allowed after preparer omitted the election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. Before investing, the taxpayer's officers and tax counsel…
PLR 1125004: Retroactive QEF election allowed after a preparer omitted the election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. Before investing, the taxpayer's officers and tax counsel…
PLR 1123044: IRS approves endowment-pool treatment for charitable trusts
The IRS approved a university's proposed treatment of investments by two charitable remainder trusts in the university's general endowment pool. The IRS ruled that issuing, holding, redeeming, and…
PLR 1123043: IRS approves capital and unrelated-business-income treatment for endowment pool units
The IRS approved a university's proposed investment of a charitable remainder unitrust in units of the university's general endowment pool. It ruled that the pool-unit arrangement, distributions,…
PLR 1123042: IRS approves capital and unrelated-business-income treatment for endowment pool units
The IRS approved a university's proposed investment of a charitable remainder unitrust in units of the university's general endowment pool. It ruled that the pool-unit arrangement, distributions,…
PLR 1122007: IRS addresses tax effects of an early trust distribution
The beneficiaries and trustees of an irrevocable trust sought court approval to distribute part of the trust principal early to the remainder beneficiaries while leaving the balance in trust. The…
CCA 1121020: commercialization agreement treated as a franchise with ordinary income consequences
Chief Counsel analyzed the tax treatment of a heavily redacted commercialization transaction involving patents, know-how, agreements, and contingent payments. The advice concluded that the taxpayer…
PLR 1120013: transaction form respected for debt repayment and stock retirement
The IRS considered a transaction in which a corporation merged with an acquisition vehicle, used transaction proceeds to repay debt owed to a shareholder and its parent, and issued warrants in…
PLR 1120012: transaction form respected for debt repayment and stock retirement
The IRS considered a transaction in which a corporation merged with an acquisition vehicle, used transaction proceeds to repay debt owed to a shareholder and its parent, and issued warrants in…
PLR 1120009: taxpayer allowed a retroactive QEF election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a foreign corporation that was later identified as a passive foreign investment company. The…
PLR 1118007: IRS approves a trust severance and disclaimer plan involving QTIP property
The IRS considered a surviving spouse's proposed disclaimer of an interest in part of a QTIP marital trust after a state-court severance. The spouse planned to disclaim the interest in one new…
PLR 1117013: Variable annuity certificate treatment for an investment account
The IRS ruled on the federal tax treatment of a proposed certificate linked to an investment account and designed to provide a future annual benefit if the account were depleted under specified…
TAM 1111004: disaster-converted inventory qualifies for the § 1033(h)(2) replacement rule
The IRS considered whether inventory destroyed or damaged in a Presidentially declared disaster qualifies as property held for productive use in a trade or business under section 1033(h)(2). The…
PLR 1111002: alternative basis recovery allowed for contingent asset-sale payments
The IRS granted a closely held S corporation permission to use an alternative method for recovering basis from a contingent-payment asset sale. The taxpayer had sold substantially all of its…
PLR 1110009: foreign electronic exchange qualifies under IRC section 1256
The IRS determined that a foreign electronic exchange qualified as a board or exchange under IRC § 1256(g)(7)(C). The exchange traded commodity futures and other futures or options, was regulated by…
PLR 1109017: The IRS withdrew three prior rulings on borrowed shares and constructive sales
The IRS withdrew three rulings in private letter ruling 200440005 concerning the delivery of borrowed shares to close out two financial contracts. The withdrawn rulings had concluded that the…
PLR 1109004: The IRS approved a trust division and related tax treatment
The trustee of an irrevocable trust asked to divide it into two successor trusts, one for each family line, and to modify several distribution and administrative provisions. The IRS addressed the…
PLR 1108022: PFIC overlap rule applies to a controlled foreign corporation owned through a partnership
The IRS ruled on the application of the PFIC overlap rule to a foreign corporation owned through a domestic partnership. The foreign corporation was expected to be both a passive foreign investment…
PLR 1108021: PFIC overlap rule applies to a controlled foreign corporation owned through a partnership
The IRS ruled on the application of the PFIC overlap rule to a foreign corporation owned through a domestic partnership. The foreign corporation was expected to be both a passive foreign investment…
PLR 1108020: PFIC overlap rule applies to specified owners of a controlled foreign corporation
The IRS ruled on the application of the PFIC overlap rule to a foreign corporation owned through a domestic partnership. The foreign corporation was expected to be both a passive foreign investment…
PLR 1107009: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a passive foreign investment company and a…
PLR 1107008: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a passive foreign investment company and a…
PLR 1107007: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a passive foreign investment company and a…
PLR 1107006: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a passive foreign investment company and a…
PLR 1107005: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a passive foreign investment company and a…
PLR 1107004: PFIC overlap rule applies to a partnership's controlled foreign corporation
The IRS ruled for a partnership that wholly owns a foreign corporation. The foreign corporation was expected to be both a passive foreign investment company and a controlled foreign corporation.…
PLR 1106003: PFIC overlap rule applies while a foreign subsidiary is a CFC
The IRS considered a domestic partnership that wholly owned a foreign corporation through a disregarded entity. The foreign corporation was expected to be both a controlled foreign corporation and a…
PLR 1105030: Proposed exchange offer receives favorable stock and debt tax treatment
A publicly traded company proposed to repurchase notes and settle related stock purchase contracts before a scheduled remarketing. The company planned to pay some holders with company stock and cash…
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…
PLR 1105004: IRS approves tax treatment of a guaranteed withdrawal annuity
A taxpayer planned to purchase a certificate tied to selected assets in a managed account. The certificate allowed withdrawals and promised a guaranteed minimum lifetime benefit if the selected…
PLR 1104001: IRS approves a settlement dividing a family trust without added transfer tax
A family asked how a proposed court-approved settlement of long-running disputes over two trusts would affect income, gift, estate, and generation-skipping transfer taxes. The settlement divided one…
PLR 1102052: Trust settlement avoids transfer taxes and gain recognition
A family sought rulings on the federal tax effects of a mediated settlement involving two trusts created under a decedent’s will. The settlement resolved long-running disputes involving the rule…
PLR 1102051: IRS approves a settlement of disputed trust interests without additional tax recognition
A family settled a long-running dispute over how two trusts should distribute income and principal to descendants. The settlement used a negotiated fractional split between competing per capita and…
PLR 1102045: IRS permits a retroactive QEF election for an undisclosed PFIC investment
A U.S. taxpayer indirectly owned shares in a passive foreign investment company through foreign trusts but did not know the investment existed. The taxpayer and several advisers provided affidavits…
PLR 1102044: IRS permits a retroactive QEF election after a PFIC interest was undisclosed
A U.S. taxpayer indirectly acquired an interest in a passive foreign investment company through foreign trusts, without receiving enough information to identify the investment or its PFIC status.…
PLR 1102024: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102023: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102022: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102021: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102020: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102019: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102018: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102017: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102016: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102015: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102014: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102013: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102012: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102011: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102010: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102009: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102008: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102007: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102006: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102005: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102004: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1101009: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101008: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101007: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
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.