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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IRS waives a 60-day IRA rollover deadline after tax advisor error
An IRA owner received a distribution larger than intended after relying on incorrect advice from her tax advisor. She sought a waiver of the 60-day rollover deadline for the excess amount and had…
IRS waives a 60-day IRA rollover deadline after medical emergencies
An IRA owner missed the 60-day rollover deadline while recovering from surgery and caring for her daughter after a serious accident. She deposited the distribution into the IRA nine days after the…
IRS waives a 60-day SEP-IRA rollover deadline after bank delay
An IRA owner withdrew money from a SEP-IRA to help purchase a home and intended to replace it using a home equity loan. The bank delayed releasing the loan proceeds because it required an original…
IRS waives a 60-day rollover deadline after a custodian error
An IRA custodian was resigning and instructed the taxpayer to complete an assignment form to transfer an asset to another IRA. The taxpayer sent the paperwork to an intermediary, but the…
IRS waives the 60-day deadline for a plan loan offset rollover
A former employee's retirement plan loan was offset and treated as a distribution after the employee's job ended. The employee missed the 60-day rollover deadline because the plan's service provider…
IRS waives the rollover deadline after a taxpayer missed a distribution notice while abroad
A retired employee was outside the country when an employer distributed the employee's vested retirement account and mailed the distribution check. The employee did not learn of the distribution…
IRS waives the 60-day deadline for an IRA rollover misdirected to an ineligible custodian
An individual received a distribution from an IRA and sent the money to a real estate investment after being told that the recipient was an eligible IRA custodian. The individual later learned that…
IRS waives the 60-day deadline after a financial institution misclassified an IRA application
An individual asked to move money from one IRA to another IRA at a different financial institution. An agent mistakenly marked the new account application as “nonqualified” instead of “IRA,” even…
IRS waives the rollover deadline for an RMD distributed from the wrong retirement plan
An individual had required minimum distributions from a qualified plan, a SEP-IRA, and a traditional IRA. A financial advisor mistakenly advised the individual to take all of the required…
IRS waives the rollover deadline after a bankruptcy disrupted a direct rollover
An individual requested a direct rollover from a retirement plan to another plan after the employer sponsoring the original plan went bankrupt. The direct rollover was not completed, and a…
IRS waives the rollover deadline after an IRA transfer went to a taxable account
An individual intended to liquidate an IRA and invest the proceeds in a fund while keeping the investment inside an IRA. The financial institution transferred the assets without obtaining the…
IRS grants 60 days to recharacterize a failed SEP IRA conversion
A taxpayer converted funds from a SEP IRA to a Roth IRA but later learned that the taxpayer's income exceeded the applicable conversion limitation. The IRS found that the taxpayer reasonably relied…
IRS grants 60 days to recharacterize a failed SEP IRA conversion
A taxpayer converted funds from a SEP IRA to a Roth IRA but later learned that the taxpayer's income exceeded the applicable conversion limitation. The IRS found that the taxpayer reasonably relied…
IRS waives the 60-day IRA rollover requirement
A taxpayer received what was represented as a duplicate required minimum distribution after a communication problem with a financial institution. The taxpayer deposited the distribution, later…
IRS waives the 60-day rollover requirement for an employee plan distribution
A taxpayer received a distribution from an employee plan and intended to roll part of it into an IRA. The taxpayer did not complete the rollover within 60 days because the taxpayer was caring for an…
IRS waives the 60-day rollover requirement for employee plan stock
A taxpayer received shares from an employee plan after a stockbroker mistakenly arranged for a stock distribution instead of the intended rollover. The taxpayer later learned that the transaction…
IRS grants 60 days to recharacterize a failed Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a failed SEP IRA to Roth IRA conversion as a contribution to a traditional IRA. The taxpayer exceeded the income limit for the Roth IRA…
IRS waives 60-day rollover deadline after a participant's death
The IRS waived the 60-day rollover deadline for a deceased retirement-plan participant's estate. The participant had received a distribution from a qualified plan and intended to roll it into an…
IRS grants 60 days to recharacterize a failed Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a failed SEP IRA to Roth IRA conversion as a contribution to a traditional IRA. The taxpayer exceeded the income limit for the Roth IRA…
IRS waives the 60-day rollover deadline after a financial institution's error
An individual asked the IRS to waive the 60-day deadline for rolling a retirement-plan distribution into an IRA. The individual had requested a trustee-to-trustee transfer, but the financial…
IRS waives the 60-day rollover deadline after IRA transfers were misdirected
An individual asked the IRS to waive the 60-day deadline after amounts from a traditional IRA and a Roth IRA were transferred into the wrong types of IRA accounts. The individual had signed transfer…
IRS waives the rollover deadline after a taxpayer cared for an ill spouse
An individual asked the IRS to waive the 60-day deadline for rolling an IRA distribution into a traditional IRA. During the rollover period, the individual's husband became seriously ill and…
IRS waives the rollover deadline after a caregiver missed it while managing dementia-related affairs
An individual acting under a durable power of attorney asked the IRS to waive the 60-day deadline for rolling over a distribution from his wife's IRA. The wife had dementia, was entering assisted…
IRS waives the rollover deadline after a broker mishandled an RMD
An individual asked the IRS to waive the 60-day deadline after a brokerage firm distributed the wrong amount from an IRA. A former broker had moved from one company to another, and the new company…
IRS waives the 60-day IRA rollover deadline after incorrect financial advice
An IRA owner missed the 60-day rollover deadline after placing a distribution into a savings account based on incorrect advice from a financial advisor. The owner deposited the amount into another…
PLR 1351032: picked-up pension contributions and plan transfers
The ruling addresses mandatory employee contributions to a governmental pension plan that the employer treated as picked-up employer contributions under IRC § 414(h)(2). It also addresses transfers…
PLR 1351031: IRS waives the 60-day rollover deadline after a spouse's death
The ruling concerns a beneficiary who received an IRA distribution after her spouse died unexpectedly. She intended to roll the distribution into an IRA, but misunderstood a financial institution's…
PLR 1351030: plan transfer and picked-up contributions do not harm qualification
The ruling addresses two governmental retirement plans sponsored by a state. One is a defined benefit plan and the other is a money purchase pension plan, and a new statute would let certain members…
PLR 1351020: bank may claim losses when it surrenders bank-owned life insurance policies
A national banking association asked how to calculate losses when it surrendered three bank-owned life insurance policies and terminated related stable-value wrap contracts. The IRS ruled that the…
PLR 1350049: financial institution error qualifies for a 60-day IRA rollover waiver
An older taxpayer received a distribution from an IRA and instructed a financial institution to deposit it into another IRA, but the institution instead placed the money in a non-IRA certificate of…
PLR 1350048: church-affiliated community's welfare plans qualify as church plans
A not-for-profit community operated health-care and senior services under a foundation connected to a church district. It maintained ten welfare benefit plans for its employees and related entities…
PLR 1349029: Transfers between disability and defined contribution plans are not taxable events
A state government maintained a defined benefit plan and a defined contribution plan for its employees. Under proposed disability procedures, a participant who became totally and permanently…
PLR 1349027: Eight plans qualify as church plans
A religious health-care community and its nonprofit affiliates maintained eight retirement, welfare, and insurance plans. They asked whether the plans qualified as church plans under Section 414(e),…
PLR 1349026: Medical emergency qualifies for a 60-day IRA rollover waiver
An individual received a distribution from an IRA and deposited it into several bank accounts. A medical emergency and hospitalization lasted beyond the 60-day rollover period, preventing the…
PLR 1349025: Failed wire transfer qualifies for a 60-day IRA rollover waiver
A taxpayer received an IRA distribution and timely attempted to wire part of it back into the IRA. The transfer failed because one digit was missing from the account number, but the financial…
PLR 1348018: IRS waives the 60-day IRA rollover requirement
An elderly taxpayer received an IRA distribution and intended to roll it into another IRA, but the receiving bank opened a non-IRA account instead. The IRS concluded that the failure to complete the…
PLR 1348017: IRS waives rollover deadlines after financial hardship and misinformation
A taxpayer received distributions from two IRAs after his wife's death and intended to roll both amounts into another IRA. He delayed because of financial and emotional stress, unfamiliarity with…
PLR 1347030: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1347029: IRS waived the 60-day IRA rollover deadline after an unexpected bank closure
The IRS waived the 60-day rollover requirement for a taxpayer who received an IRA distribution after the unexpected closure of the financial institution holding the IRA. The distribution check did…
PLR 1347028: IRS denied special pension-limit treatment for a state corrections department
The IRS concluded that a state corrections department was not a police department for purposes of the special age-reduced pension-limit exception in IRC § 415(b)(2)(G). The department performed…
PLR 1347027: IRS waived the 60-day IRA rollover deadline because of the taxpayer's medical condition
The IRS waived the 60-day rollover requirement for an elderly taxpayer whose medical condition impaired his ability to manage his financial affairs. He received a distribution from an IRA, deposited…
PLR 1347026: IRS waived the 60-day IRA rollover deadline after a financial institution's deposit error
The IRS waived the 60-day rollover requirement after a financial institution deposited an IRA distribution into a non-IRA account despite the taxpayer's instruction to deposit it into an IRA. The…
PLR 1347025: IRS waived rollover deadlines after an IRA stock-purchase error and incorrect IRS advice
The IRS waived the 60-day rollover requirement for two distributions from a taxpayer's IRA. The first arose after an IRA custodian treated a stock purchase as a distribution and the taxpayer's…
PLR 1346013: IRS waives the 60-day rollover deadline for an unrequested inherited-plan distribution
A beneficiary received an unrequested distribution from a deceased spouse's qualified retirement plan and missed the 60-day rollover deadline. The beneficiary said the plan did not provide the…
PLR 1345042: IRS recognizes a retirement plan as a church plan retroactive to 1974
The IRS ruled that a retirement plan sponsored by a nonprofit hospital and its successor parent organization qualified as a church plan under IRC § 414(e). The organizations were exempt under…
PLR 1345041: IRS recognizes two retirement plans as church plans
The IRS ruled that two retirement plans sponsored by a nonprofit religious organization qualified as church plans under IRC § 414(e). The organization was associated with a religious conference,…
PLR 1345040: IRS waives the 60-day IRA rollover deadline after bank error
The IRS granted a taxpayer 60 days from the ruling date to contribute a distribution to a rollover IRA. The taxpayer intended to move money from an existing IRA into another IRA, but a financial…
PLR 1345039: IRS waives the 60-day IRA rollover deadline after a mistaken deposit
The IRS waived the 60-day IRA rollover requirement for part of a taxpayer's distribution. The taxpayer had repeatedly reinvested IRA assets in consecutive 12-month IRA certificates of deposit, but…
PLR 1345038: IRS waives the IRA rollover deadline after an invalid custodian error
The IRS waived the 60-day rollover requirement for a taxpayer who deposited IRA funds with a financial institution that was not qualified to serve as an IRA custodian. The taxpayer relied on an…
PLR 1345037: IRS waives the IRA rollover deadline after an invalid custodian error
The IRS waived the 60-day rollover requirement for a taxpayer who directly transferred IRA funds to a financial institution that was not qualified to serve as an IRA custodian. The taxpayer relied…
PLR 1345036: IRS waives the rollover deadline after a clerical account error
The IRS waived the 60-day rollover requirement for a retired school teacher who received a distribution from a section 403(b) annuity plan. The taxpayer intended to place the funds in an IRA, but a…
PLR 1344012: IRA rollover deadline waived after hospitalization
An IRA owner received a distribution and did not complete the rollover within the 60-day period because of hospitalization and recuperation. The IRS waived the 60-day requirement under section…
Other 1343031: IRS grants a conditional pension minimum funding waiver
The IRS granted a conditional waiver of the required minimum funding contribution for a pension plan for the year ending December 31, 2012. The company had experienced temporary business hardship…
PLR 1343030: IRS waives the 60-day IRA rollover deadline after a medical condition caused an excess withdrawal
A taxpayer intended to withdraw only a required minimum distribution from an IRA but instead withdrew the entire account balance. The taxpayer attributed the mistake and the missed 60-day rollover…
PLR 1343029: IRS waives the 60-day rollover deadline after a financial institution error
After leaving employment, a taxpayer received a distribution from an employee plan and intended to roll the entire amount into an IRA or another qualified plan. The plan administrator correctly…
PLR 1342019: IRS waives the 60-day IRA rollover deadline after a bank error
The IRS waived the 60-day deadline for an IRA rollover after a bank employee deposited a taxpayer's distribution into a non-IRA account. The taxpayer had taken the distribution check to the bank on…
PLR 1342017: IRS waives rollover deadline after fraudulent IRA custodian activity
The IRS waived the 60-day rollover requirement for a taxpayer whose retirement funds were transferred to an entity that was falsely represented as a qualified IRA custodian. The taxpayer intended to…
PLR 1342016: IRS waives rollover deadline after a medical condition impairs timely action
The IRS waived the 60-day rollover requirement for a taxpayer who transferred retirement funds to a non-IRA account while experiencing severe stress, anxiety, and a documented medical condition…
PLR 1342015: IRS waives rollover deadline after reliance on erroneous financial advice
The IRS waived the 60-day rollover requirement for a taxpayer who relied on erroneous advice from a financial advisor after receiving a distribution from an IRA annuity. The taxpayer invested the…
PLR 1341041: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covers liabilities described under sections 431(b)(2)(B) and 431(b)(4) 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.