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 1101006: 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 1101005: 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 1101004: 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 1101003: 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 1101002: 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 1101001: 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 1052002: Court-approved trust settlement does not trigger the described tax consequences
A trust's beneficiaries were litigating how trust income and principal should be distributed under a will, a later agreement, and state law. They proposed a court-approved settlement that divided…
PLR 1051023: Trust settlement will not trigger GST, gift, estate, or income tax
The IRS considered a proposed settlement of litigation over two trusts created under a deceased person's will. The dispute concerned the rule against perpetuities, how trust principal and income…
PLR 1051020: Foreign stock exchange gain may count toward loss limitation
A consolidated corporate group in bankruptcy proposed to move foreign subsidiary stock to a new disregarded LLC and then transfer the LLC interests to creditors. The IRS ruled that the resulting…
PLR 1051004: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051003: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051002: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1050008: IRS approved consolidating three trusts without triggering new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050006: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050005: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1049024: Surviving corporation must use specified methods for loan fee OID
This ruling addresses a merger in which the surviving corporation inherited the predecessor's accounting-method items under IRC § 381. The corporations had used different methods to account for…
PLR 1049006: Upstream merger will not trigger gain on installment note
This ruling addresses a proposed upstream merger in which a subsidiary would transfer an installment note to its parent. The IRS concluded that the transfer would not be a taxable disposition of 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.