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 1349008: IRS grants more time for a consolidated group’s NOL carryback election
The IRS granted a consolidated group 60 days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline and represented…
PLR 1349006: Proposed spin-off qualifies as a tax-free reorganization
A parent corporation proposed to separate one business into a newly formed subsidiary and distribute the subsidiary's stock to the parent's shareholders. The plan also included exchanging some…
PLR 1348011: IRS permits limited nonrecognition in a foreign-parent liquidation
A foreign parent corporation proposed to liquidate its U.S. subsidiary after transferring the assets and liabilities of two operating subsidiaries to a new limited partnership. The IRS ruled that…
PLR 1348006: IRS approves a tax-deferred transfer of structured settlement assets to a new corporation
A group of insurance companies planned to move structured settlement annuities and related payment obligations from a subsidiary being liquidated into a new corporation. The IRS ruled that the…
PLR 1348005: IRS approves a tax-free spin-off of a controlled subsidiary
A publicly traded corporation planned to separate one business from its other operations by distributing all of the stock of its controlled subsidiary to its shareholders. The IRS ruled that the…
PLR 1347011: IRS grants a 45-day extension for a late consolidated-return election
A corporate parent and three subsidiaries missed the deadline to elect to file a consolidated federal income tax return. The parent asked the IRS for relief under the regulations that allow extra…
PLR 1347005: IRS approves tax treatment for a three-stage corporate spin-off restructuring
A holding company requested rulings on the federal tax consequences of a restructuring that separated one business from another through contributions and three distributions of controlled-company…
PLR 1345023: Convertible notes will not be treated as stock for section 382 purposes
A corporation in bankruptcy asked whether its publicly traded convertible notes would be treated as stock when applying the ownership-change rules of IRC section 382. The corporation had substantial…
PLR 1344005: IRS grants extra time for a consolidated group to elect an extended NOL carryback
A consolidated corporate group incurred a consolidated net operating loss and missed the deadline to elect an extended carryback period. The group requested relief after discovering that the…
PLR 1343012: accounting method changes granted for six liability categories
The IRS granted a corporation permission to change how it accounts for six categories of liabilities after a merger, including advertising and program services, royalties, equipment disposal and…
PLR 1342008: IRS grants more time to waive a consolidated NOL carryback
A consolidated corporate group asked for more time to file an election waiving the carryback period for a consolidated net operating loss. The group represented that it had not carried the loss back…
PLR 1342005: IRS grants more time to make an extended NOL carryback election
A successor agent for a consolidated corporate group asked for more time to make an election extending the carryback period for a consolidated net operating loss. The election was intended to carry…
PLR 1342004: IRS allows transferred business assets to be counted in a consolidated group's SRLY subgroup calculations
A corporate group combined a surviving consolidated group with a terminating consolidated group. As part of the integration, two subsidiaries merged into another subsidiary, which then transferred a…
PLR 1341026: IRS confirms supplemental spin-off facts do not affect prior rulings
The IRS issued a supplemental ruling for a planned distribution of a controlled corporation's stock to the distributing corporation's shareholders. The changes included a different cash…
PLR 1341022: IRS grants late consolidated-group intercompany election relief
The IRS granted a consolidated group 45 days to file a late election under section 1.1502-13(l)(3) for certain intercompany stock transactions. The group represented that it reasonably relied on a…
PLR 1341018: IRS preserves a life-nonlife consolidated group after a merger
The IRS ruled that a life-nonlife consolidated group would remain in existence after its common parent merged with a subsidiary and public shareholders received stock in a new common parent. The…
PLR 1341013: IRS approves tax treatment for a proposed corporate separation
The IRS ruled on the federal tax treatment of a proposed separation of two businesses operated within a corporate group. The transaction would transfer one business to a new subsidiary, distribute…
PLR 1341008: IRS grants more time to elect consolidated return filing
The IRS granted a parent company and its subsidiaries more time to elect to file a consolidated federal income tax return. The group intended to make the election but did not file it by the…
PLR 1341004: IRS approves a tax-free separation of two businesses
The IRS approved the proposed separation of two businesses operated within an affiliated corporate group. One corporation would contribute the assets of one business to a newly formed controlled…
CCA 1340016: Chief Counsel advises respecting cross-border reorganizations and debt repayments
Chief Counsel analyzed whether the IRS should issue a notice of deficiency concerning a multinational group's two-stage restructuring. The advice concluded that the first reorganization and the…
PLR 1340009: IRS approves a two-stage REIT spin-off and related reorganizations
The IRS approved the federal tax treatment of a proposed two-stage restructuring involving a publicly traded real estate investment trust, two distributing corporations, and a newly formed…
PLR 1340003: IRS grants more time for a consolidated NOL carryback election
The IRS granted a consolidated corporate group 60 days to make a late election for an extended carryback period for a consolidated net operating loss. The group represented that it intended to make…
PLR 1339001: Corporate group may separate business lines through multi-step reorganizations
A publicly traded corporate group proposed a series of domestic and international reorganizations to separate two business lines. The plan included internal distributions, entity conversions,…
PLR 1338040: IRS approves tax treatment for a corporate spin-off and related asset transfers
A publicly traded parent corporation planned to separate two business lines through internal subsidiary distributions, asset contributions, a contribution of Sub 1 to a newly formed Controlled…
PLR 1338025: IRS grants more time to elect consolidated-return treatment
A parent company discovered that a subsidiary group had filed consolidated returns with the wrong common parent and that another dormant subsidiary had been omitted from one return. The parent…
PLR 1338019: IRS grants a consolidated group more time to elect an extended net operating loss carryback
A consolidated group incurred a net operating loss and failed to timely elect an extended carryback period for that loss. The group asked for more time under the relief rules for late regulatory…
PLR 1338017: IRS grants more time to elect consolidated return treatment
A parent and three subsidiaries wanted to file their first consolidated federal income tax return, but the election was not timely filed. The parent asked for relief under the late-election rules.…
PLR 1338011: IRS grants more time to make section 338 elections for foreign targets
A U.S. parent and its foreign subsidiary acquired all of the stock of two foreign corporations and intended to make section 338(g) elections. The elections were not timely filed, and the parent…
PLR 1337007: IRS approves a complex corporate spin-off, mergers, liquidations, and related REIT tax treatment
A publicly traded corporate group requested rulings on a planned separation of businesses through distributions, contributions, mergers, liquidations, and related transactions. The IRS ruled on the…
PLR 1337003: IRS approves a Type D reorganization and tax-free split-off
An operating corporation owned two businesses and planned to exchange property, contribute assets and one business to a newly formed corporation, and distribute the new corporation's stock to one…
CCA 1336018: Loan interest payable in related-party stock does not reduce foreign-share basis
Chief Counsel advised that a loan’s principal amount should not reduce the taxpayer’s adjusted basis in shares of a related foreign corporation when the loan interest is optionally payable in that…
PLR 1336012: IRS approves a tax-free separation of an S corporation subsidiary
An S corporation proposed to separate a wholly owned subsidiary that operated a different business. The plan involved a deemed contribution of assets to the subsidiary, a pro rata distribution of…
PLR 1336008: IRS grants more time for an extended consolidated NOL carryback election
A consolidated corporate group incurred a net operating loss and wanted to use the extended carryback period available under IRC § 172(b)(1)(H). The group missed the deadline to make the election…
PLR 1336007: IRS grants more time to elect consolidated return filing
A corporate parent and its subsidiary wanted to file a consolidated federal income tax return, but they missed the regulatory deadline to make the election. The parent said it reasonably relied on a…
PLR 1336004: IRS grants more time to waive a consolidated NOL carryback
A consolidated corporate group wanted to elect to relinquish the entire carryback period for a consolidated net operating loss under Treas. Reg. § 1.1502-21(b)(3)(i), but the election was not timely…
PLR 1336002: IRS grants more time for an extended consolidated NOL carryback election
A consolidated corporate group incurred a net operating loss and wanted to use the extended carryback period available under IRC § 172(b)(1)(H). The group missed the deadline to make the election…
IRS allows a late election to restore value after an ownership change
The IRS granted a consolidated group an extension of time to file an election under the regulations governing § 382 limitations after an ownership change. A loss corporation had reduced its value…
IRS grants more time for a consolidated NOL carryback election
The IRS granted a consolidated group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group had failed to make a valid election to carry back a…
IRS approves a tax-free spin-off separating two business lines
The IRS approved the proposed contribution of two subsidiaries and a disregarded LLC to a newly formed subsidiary, followed by a pro rata distribution of the new subsidiary's stock to the parent…
IRS approves a tax-free corporate spin-off and internal restructuring
The IRS ruled that a corporation's proposed separation of two businesses, including an internal restructuring and a pro rata distribution of a controlled corporation's stock, would qualify under the…
IRS approves a complex corporate spin-off and related reorganizations
The IRS approved a proposed separation in which a publicly traded parent would reorganize many domestic and foreign subsidiaries, move operating businesses and assets among new and existing…
IRS rules on a stock sale and subsidiary liquidation in a consolidated group
The IRS supplemented an earlier private letter ruling on a consolidated group's planned sale of part of a subsidiary's stock followed by the subsidiary's possible complete liquidation. The ruling…
PLR 1333007: IRS approves a series of redacted corporate reorganizations and distributions
A corporate group requested rulings on a multi-step plan involving mergers, liquidations, contributions, stock distributions, and related transactions among several redacted entities. The IRS ruled…
PLR 1333003: IRS approves active-business treatment for a planned section 355 distribution
A corporate group proposed contributing assets and liabilities to a new controlled corporation and distributing that corporation's stock to a shareholder under IRC § 355. The group represented that…
PLR 1330022 approves tax treatment for multiple corporate separations
The IRS grants requested rulings concerning two internal spin-offs, a foreign parent's reincorporation, and a later demerger separating two businesses. It treats the first and second internal…
PLR 1330018 approves a merger and redemption transaction for an S corporation
The IRS rules on a proposed transaction involving an S corporation, its continuing shareholders, and a minority shareholder. The continuing shareholders will form a new corporation, contribute their…
PLR 1330017 approves a merger and redemption transaction for an S corporation
The IRS rules on a proposed transaction involving an S corporation, its continuing shareholders, and a minority shareholder. The continuing shareholders will form a new corporation, contribute their…
PLR 1330007 approves a tax-free separation of two corporate businesses
The IRS rules that a planned contribution and distribution will qualify as a tax-free reorganization under IRC § 368(a)(1)(D) and a tax-free separation under § 355. The transaction separates one…
PLR 1330004 approves tax treatment for a related-company stock sale and liquidation
The IRS rules on a proposed sale of stock within a consolidated corporate group followed by the liquidation of the sold subsidiary. The stock sale will be treated under IRC § 304 as a deemed stock…
PLR 1330002 approves a multinational separation of Business 2
The IRS rules on a large corporate restructuring intended to separate Business 2 from Business 1 and the taxpayer's other businesses. The proposed steps include foreign and domestic asset transfers,…
PLR 1330001 grants more time to waive a consolidated net operating loss carryback
The IRS grants a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group intended to make the election but…
PLR 1329014: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329013: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329012: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329011: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329010: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329009: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329008: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329007: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329006: IRS treats subsidiaries as having filed required consolidated-return consents
The IRS treated two subsidiaries as if they had filed the required Forms 1122 to join their parent’s consolidated federal income tax return. The group had filed a consolidated return and included…
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.