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.

40,104 determinations and counting · Newest release October 9, 2026
40,104 determinations

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PLR

Five healthcare-system retirement and welfare plans qualify as church plans

A tax-exempt healthcare system affiliated with a church asked whether five defined-benefit, defined-contribution, Section 403(b), welfare, and acquired retirement plans qualify as church plans. The…

202548003·November 28, 2025
Approved
PLR

Form 8996 filed with a late first-year return is treated as timely

A partnership was formed to invest in, manage, and dispose of qualified opportunity zone property and began operating as a Qualified Opportunity Fund. It did not engage an accounting firm until 14…

202548002·November 28, 2025
Approved
PLR

Corporation receives 120 days to make late S election

A corporation was eligible and intended to elect S corporation treatment from its incorporation date but failed to file Form 2553. The IRS found reasonable cause for the missed deadline and granted…

202548001·November 28, 2025
Approved
DET

IRS approves scholarship and internship grant procedures

A private foundation asked the IRS to approve two grant programs supporting historically underserved and underrepresented students. Program 1 provides renewable scholarships for direct and indirect…

202547024·November 21, 2025
Approved
DET

Charity lost exemption after transferring its operations and funds to a founder-owned business

A charity transferred its principal exempt operation to a for-profit limited liability company owned and operated by its founders. It received no consideration for the transfer and also sent the…

202547023·November 21, 2025
Revocation
DET

Farmers market denied exemption because it primarily benefited participating vendors

An organization applied for recognition as a charity based on operating a farmers market. It spent all of its time hosting weekly summer markets and one fall market where farmers and other small…

202547022·November 21, 2025
Denied
DET

Shopping center property association denied business-league exemption

A commercial property owners' association sought exemption as a business league under IRC § 501(c)(6). Membership was compulsory for owners in one shopping center, voting power and dues depended on…

202547021·November 21, 2025
Denied
DET

Housing organization lost exemption after discontinuing its exempt operations

The IRS revoked the section 501(c)(3) exemption of an organization formed to alleviate a redacted housing shortage. The organization no longer owned or operated housing facilities, had not owned…

202547020·November 21, 2025
Revocation
CCA

Incorrect address for partnership audit notice did not prevent a final adjustment

Chief Counsel considered whether the IRS could issue a final partnership adjustment after failing to mail an initial audit notice to the partnership representative's last known address. The advice…

202547019·November 21, 2025
Advice
CCA

IRS could not first disclose tax-debt information solely for criminal sentencing

A U.S. Attorney's Office wanted information about a taxpayer's unpaid taxes for sentencing in a federal drug-trafficking case. Chief Counsel advised that the IRS could not disclose it. The case did…

202547018·November 21, 2025
Advice
CCA

Erroneous examination letter did not need reissuance after partnership audit notice

Chief Counsel was asked whether the IRS needed to reissue Letter 2205-D after a notice of administrative proceeding had already been issued in a centralized partnership audit. The advice said no.…

202547017·November 21, 2025
Advice
CCA

Sports-betting winnings paid to nonresident alien required 30 percent withholding

Chief Counsel addressed U.S. withholding on sports-betting winnings paid to a nonresident alien. For a U.S. taxpayer, the payment would not have triggered Form W-2G reporting or withholding under…

202547016·November 21, 2025
Advice
CCA

Authorized manager validly replaced deceased partnership representative

Chief Counsel reviewed whether a manager could use Form 8979 to revoke and replace a partnership representative even though the manager had not been a partner during the reviewed tax year. The Form…

202547015·November 21, 2025
Advice
CCA

Marked copy of Form 1040 could qualify as the taxpayers' original return

Married taxpayers responded to an IRS notice that no return was on file by sending signed pages 1 and 2 of a joint Form 1040 clearly stamped “Copy.” Chief Counsel concluded that the submission…

202547014·November 21, 2025
Advice
PLR

Corporate group received 120 days to make late GILTI high-tax exclusion election

A U.S. corporate group intended to elect the high-tax exclusion when calculating global intangible low-taxed income for its controlled foreign corporations. Its timely return consistently computed…

202547013·November 21, 2025
Approved
PLR

Estate received 120 days to correct omitted QTIP election

A decedent's revocable trust divided at death into a bypass trust and a marital trust for the surviving spouse. The marital trust required all income to be paid to the spouse at least annually,…

202547012·November 21, 2025
Approved
PLR

Fund received 60 days to file late qualified opportunity fund certifications

A limited liability company was formed to qualify as a qualified opportunity fund and invest in qualified opportunity zone property. It hired an experienced accountant who knew that intent and was…

202547010·November 21, 2025
Approved
PLR

Partnership received 120 days to make late section 754 election

A domestic limited liability company treated as a partnership sold ownership interests to a new buyer and intended to make an IRC § 754 election for that year. It inadvertently failed to attach a…

202547009·November 21, 2025
Approved
PLR

Reorganized partnership received 120 days to make late section 754 election

A limited liability company treated as a partnership reorganized under another state's law, after which two parties acquired interests in it. The partnership intended to make an IRC § 754 election…

202547008·November 21, 2025
Approved
PLR

Pension plans may use section 401(h) accounts for annuitized retirees' health benefits

An employer transferred responsibility for pension payments for a group of retirees to an insurance company through a group annuity contract. Before that transfer, the employer's pension plans used…

202547007·November 21, 2025
Approved
PLR

Donor received 120 days to elect out of automatic GST exemption allocation

A married couple made gifts to an irrevocable trust primarily benefiting their children. The trust had generation-skipping transfer potential, but the couple did not intend to allocate GST exemption…

202547006·November 21, 2025
Approved
PLR

Dividing a pre-1985 grandfathered trust into family sub-trusts keeps GST exemption and triggers no gift or estate tax

Trusts that were irrevocable before September 25, 1985 are "grandfathered" and completely exempt from the generation-skipping transfer (GST) tax, but that protected status can be lost if the trust…

202547005·November 21, 2025
Approved
PLR

120-day extension for an estate to make a late portability (DSUE) election

When a married person dies without using all of their federal estate-tax exclusion, the unused amount (the "deceased spousal unused exclusion," or DSUE) can be passed to the surviving spouse, but…

202547004·November 21, 2025
Approved
PLR

Extension of time for an estate to make a late alternate valuation election under section 2032

The estate tax is normally based on the value of a decedent's property at the date of death, but section 2032 lets the executor elect "alternate valuation," valuing the property six months later,…

202547003·November 21, 2025
Approved
PLR

120-day relief to elect out of automatic GST exemption allocation on gifts to a trust

The generation-skipping transfer (GST) tax applies when wealth passes to grandchildren or later generations. Each person has a GST exemption that can shelter transfers, and when someone makes an…

202547002·November 21, 2025
Approved
PLR

120-day relief for two late elections tied to a tax-exempt-owned low-income housing entity

When property is used by a tax-exempt entity, special "tax-exempt use property" rules force the owner to depreciate it slowly under the alternative depreciation system, which shrinks the deductions.…

202547001·November 21, 2025
Approved
DET

Subsidiary was treated as consenting to parent's consolidated return

A medical-device parent formed a domestic subsidiary to acquire another business's assets. Its tax preparer mistakenly believed the subsidiary was a disregarded entity, so the parent filed a…

202540029·October 3, 2025
Approved
DET

Domestic subsidiary was allowed to join parent's consolidated return late

A parent corporation owned a foreign subsidiary that in turn owned a domestic subsidiary. After another group acquired the parent, advisers failed to identify that the foreign subsidiary held U.S.…

202540028·October 3, 2025
Approved
DET

Pension plan approved to use plan-specific substitute mortality tables

A pension plan sponsor requested permission to use mortality tables based on the plan's own experience instead of the standard tables used for minimum-funding calculations. The plan used a five-year…

202540027·October 3, 2025
Approved
DET

Charity lost exemption after failing to document any exempt activity

A charitable and scientific organization did not respond to repeated IRS requests for records during an examination. The IRS tried the organization and its officers at several addresses, and…

202540026·October 3, 2025
Revocation
DET

Trust for one injured person did not serve a public charitable interest

A group formed a special needs trust to raise and manage money for one named person with a traumatic brain injury. The trust would pay that person's medical, rehabilitation, transportation, food,…

202540025·October 3, 2025
Denied
DET

College athlete NIL collective primarily served private interests

A nonprofit planned to fund name, image, and likeness sponsorships for selected men's and women's basketball players at one college. The athletes would promote the college and charities through…

202540024·October 3, 2025
Denied
DET

Small-business marketplace LLC failed organizational and operational tests

An LLC operated a weekend marketplace where small businesses paid for space to sell goods and services. It marketed the venue, provided entertainment to attract customers, and offered members…

202540023·October 3, 2025
Denied
DET

Same-first-name social events did not qualify as charitable activity

An organization sought recognition as a charity for hosting events around the country for people who share the same first name. It organized themed gatherings, managed social media communities,…

202540022·October 3, 2025
Denied
DET

Referral network served members rather than a line of business

A professional networking organization sought exemption as a business league under IRC § 501(c)(6). Its members came from different industries, met weekly to exchange referrals, and were limited to…

202540021·October 3, 2025
Denied
DET

Public golf fundraiser produced too much nonmember income

A membership organization sought exemption as a social club under IRC § 501(c)(7). It held an annual golf fundraiser open to members and the public, solicited public donations and sponsorships, and…

202540020·October 3, 2025
Denied
DET

Homeowners association primarily benefited private property owners

A homeowners association sought exemption as a social welfare organization under IRC § 501(c)(4). It maintained common areas and the front yards of private lots, funded those services through owner…

202540019·October 3, 2025
Denied
DET

IRS revokes 501(c)(3) status of a charity that ran a private poker club, for gaming as its primary activity and inurement to its director

The IRS revoked the tax-exempt charity status of an organization whose main activity was running a private, members-only poker club (daily poker tournaments, casino nights) that operated seven days…

202540018·October 3, 2025
Revocation
DET

Gated common areas served homeowners rather than the public

A homeowners association sought exemption as a social welfare organization under IRC § 501(c)(4). It maintained lawns, a common driveway, and access areas for its members, funded entirely by…

202540017·October 3, 2025
Denied
DET

Labor representation primarily benefited union members

A labor union association sought recognition as a charity under IRC § 501(c)(3). It represented members in collective bargaining, grievances, workplace safety, and employment conditions. It also…

202540016·October 3, 2025
Denied
DET

Expatriate social club did not serve charitable or educational purposes

An organization created a community for expatriates from the same homeland and sought exemption under IRC § 501(c)(3). It used member dues for happy hours, sports competitions, tickets, trips, and…

202540015·October 3, 2025
Denied
DET

Dominoes club primarily served members' recreation

A hobby club sought recognition as a charity under IRC § 501(c)(3). Its members would socialize and play dominoes at activities closed to the public. The club expected to use its small budget for…

202540014·October 3, 2025
Denied
DET

Rodeo organization had substantial recreational purposes

An organization that was already exempt under IRC § 501(c)(4) applied for recognition as a charity under IRC § 501(c)(3). Its main activity was planning, fundraising for, and conducting an annual…

202540013·October 3, 2025
Denied
DET

Fundraising credits primarily benefited participating families

A booster club sought recognition as a charity under IRC § 501(c)(3) to support youth arts and athletics. Members volunteered at concession stands and received fundraising credits based on the…

202540012·October 3, 2025
Denied
DET

Dog training and trials were not exclusively educational

A dog club applied for recognition as an educational charity under IRC § 501(c)(3). It planned to offer paid dog-training sessions, clinics, seminars, and competitive dog trials, with the dogs as…

202540011·October 3, 2025
Denied
DET

Motorcycle club primarily served social and recreational purposes

A motorcycle club applied for recognition as a charity under IRC § 501(c)(3). Members paid dues for a clubhouse and utilities, met for motorcycle rides, held picnics, played horseshoes, and invited…

202540010·October 3, 2025
Denied
DET

Condominium landscaping primarily benefited unit owners

A condominium homeowners association applied for recognition as a charity under IRC § 501(c)(3). It collected monthly dues to maintain landscaping and pay expenses for common property next to a…

202540009·October 3, 2025
Denied
PLR

LLC receives relief for late corporate and S corporation elections

A limited liability company intended to be classified as a corporation and treated as an S corporation from the same effective date. It failed to file Form 2553, which could have produced a deemed…

202540008·October 3, 2025
Approved
PLR

Partnership may make late election to defer housing credit period

A partnership placed a low-income housing building in service but intended to begin its ten-year credit period in the following taxable year. It filed Form 8609 without timely making the irrevocable…

202540007·October 3, 2025
Approved
PLR

Building owner may correct housing credit period election

A building owner intended to begin a low-income housing building's ten-year credit period in the year after the building was placed in service. Its preparer instead checked “No” on line 10a of Form…

202540006·October 3, 2025
Approved
PLR

LLC receives extension for late corporate classification election

A limited liability company intended to be classified as an association taxable as a corporation but failed to file Form 8832 by the deadline. The IRS concluded that the company satisfied the…

202540005·October 3, 2025
Approved
PLR

Estate receives extension to elect portability

An estate that was not otherwise required to file an estate tax return missed the deadline to elect portability of the decedent's unused estate and gift tax exclusion to the surviving spouse. The…

202540004·October 3, 2025
Approved
PLR

Successor receives extension for late QSub election

An S corporation intended to elect qualified subchapter S subsidiary status for a wholly owned subsidiary but failed to file Form 8869. A later parent corporation acquired the first S corporation in…

202540003·October 3, 2025
Approved
PLR

REIT and subsidiary receive extension for late TRS election

A REIT formed a wholly owned subsidiary to hold employee-housing leases connected with a hotel acquisition and intended the subsidiary to be a taxable REIT subsidiary. Its accounting firm's…

202540002·October 3, 2025
Approved
PLR

Partnership receives extension for late section 754 election

A partnership intended to elect under IRC § 754 to adjust the basis of partnership property but omitted the election from its timely filed return. The IRS concluded that the partnership satisfied…

202540001·October 3, 2025
Approved
DET

Intergenerational fellowship grant procedures approved

A private foundation requested advance approval under IRC § 4945(g)(3) for a one-year fellowship supporting emerging practitioners in intergenerational work. Each award combined project support with…

202539018·September 26, 2025
Approved
DET

Merger transfer qualifies as an unusual grant

A publicly supported charity operating an equine-therapy and educational center planned to merge with its Type I supporting organization. The charity would survive and receive all of the supporting…

202539017·September 26, 2025
Approved
PLR

Three pension plans may use substitute mortality tables for five years

A sponsor of three defined benefit pension plans asked to use plan-specific substitute mortality tables when computing minimum funding obligations under IRC § 430. The request covered male and…

202539016·September 26, 2025
Approved
DET

Foundation's arts-center set-aside approved

A private foundation requested approval to set aside funds for the startup of an inclusive arts, vocational-training, and community-engagement center. The project included research and legal…

202539015·September 26, 2025
Approved
DET

Tax-services organization denied social-welfare exemption

A nonprofit sought exemption under IRC § 501(c)(4) for a membership-based tax-services operation that also planned taxpayer education and some free help for people facing hardship. Members paid an…

202539014·September 26, 2025
Denied

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.