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 1341040: IRS grants a minimum-funding waiver to a financially distressed pension plan
The IRS granted a private company's request for a waiver of the minimum funding standard for its pension plan for the plan year ending December 31, 2011. The waiver was subject to conditions…
PLR 1341039: IRS waives the 60-day deadline for an IRA rollover after a family death
An individual received a distribution from an IRA but did not complete the rollover within 60 days. She said that grief after her father's death and the work of preparing his memorial service…
PLR 1341038: IRS waives the 60-day rollover deadline after conflicting advice and a family illness
The IRS revised an earlier ruling and waived the 60-day deadline for rolling a retirement-plan distribution into an IRA. The taxpayer said that conflicting advice from a credit union and a tax…
PLR 1340026: IRS approves picked-up pension contributions as employer contributions
The IRS ruled that mandatory pension contributions deducted from certain public employees' salaries and paid to a state retirement plan by participating employers would be treated as employer…
PLR 1340025: IRS waives the 60-day IRA rollover deadline after health problems
The IRS waived the 60-day deadline for two taxpayers to roll distributions from individual retirement accounts into rollover IRAs. One taxpayer's worsening health problems prevented a timely…
PLR 1340024: IRS waives the rollover deadline after a duplicate required distribution
The IRS waived the 60-day rollover requirement for a taxpayer who received a duplicate required minimum distribution from an IRA. A financial advisor failed to account for an earlier distribution…
PLR 1340023: IRS waives a 60-day IRA rollover deadline after a financial institution error
The IRS granted an individual a waiver of the 60-day deadline for rolling an IRA distribution into a rollover IRA. The individual had asked the financial institution whether another required minimum…
Determination 1339004: School's retirement and welfare plans qualified as church plans
The IRS ruled that a school's tax-sheltered annuity plan and health and welfare plan were church plans under section 414(e). The school was affiliated with a church through its founding…
Determination 1339003: IRS declined a waiver of the 60-day IRA rollover rule
The IRS declined to waive the 60-day requirement for a taxpayer who withdrew money from an IRA and later tried to deposit it into a rollover IRA. The taxpayer said that Bank A failed to advise him…
PLR 1339002: IRS declines to waive the 60-day IRA rollover requirement
An individual received distributions from three IRAs and asked the IRS to waive the 60-day rollover deadline so the money could be deposited into a new rollover IRA. The individual said the delay…
PLR 1338058: IRS waives 60-day rollover deadline after financial institution error
An individual received an IRA distribution and asked the IRS to waive the 60-day rollover deadline for part of the amount. A financial institution employee advised the individual to divide the…
PLR 1338057: IRS waives rollover deadline after annuity transfer error
An individual inherited an IRA and asked the IRS to waive the 60-day rollover deadline after a financial institution transferred the distribution into a non-IRA annuity instead of the intended…
PLR 1338056: IRS waives rollover deadline after medical impairment
An individual received an IRA distribution but missed the 60-day rollover deadline after a medical condition impaired the individual’s ability to manage financial affairs. The distribution was…
PLR 1337019: IRS grants a conditional waiver of pension plan minimum funding contributions
A publishing company asked the IRS to waive required minimum funding contributions for its pension plan for two redacted plan years. The IRS granted the waiver because the company showed temporary…
PLR 1336023: IRS waives the 60-day rollover deadline for an IRA distribution
A taxpayer received an IRA distribution and attempted to roll it into an employer plan within the 60-day period. The plan recordkeeper returned the check while requesting additional paperwork, and…
PLR 1336022: IRS waives the 60-day rollover deadline for an IRA investment
A taxpayer’s IRA custodian stopped serving as custodian for an investment in a limited partnership and treated the investment as distributed. The taxpayer did not realize that the investment had…
PLR 1336021: IRS declines to waive the 60-day rollover deadline for unused home-purchase funds
A taxpayer withdrew money from an IRA to use toward a home purchase and intended to return the unused amount after the closing. The sale of the taxpayer’s existing home was delayed, and the unused…
IRS waives the 60-day rollover deadline after the account owner's death
The IRS waived the 60-day rollover requirement for a distribution from a deceased individual's Simplified Employee Pension, or SEP, account. The surviving spouse said the account owner intended to…
IRS recognizes a university retirement plan as a church plan retroactively
The IRS ruled that a private university's defined contribution retirement plan qualified as a church plan under IRC § 414(e). The university was tax-exempt, closely connected to a religious order,…
IRS waives the 60-day rollover deadline for an excess IRA distribution
The IRS waived the 60-day deadline for rolling an excess individual retirement account distribution into an IRA. The taxpayer received a second required minimum distribution because the financial…
IRS waives the 60-day rollover deadline after an advisor's paperwork error
The IRS waived the 60-day deadline for rolling a taxpayer's IRA distribution into a rollover IRA. The taxpayer withdrew funds to use as a short-term loan for a home purchase and intended to put them…
IRS waives the 60-day rollover deadline after inaccurate advisor information
The IRS waived the 60-day deadline for rolling an IRA distribution into an IRA. The taxpayer withdrew the funds after a financial advisor incorrectly said that more than 60 days were available for…
PLR 1332016: IRS declines to waive the 60-day IRA rollover deadline
The IRS declined to waive the 60-day rollover requirement for a taxpayer who took money from an IRA and used it to pay the mortgage on a primary residence. The taxpayer expected to replenish the IRA…
PLR 1331012: IRS declines to waive the 60-day IRA rollover deadline
The IRS declined to waive the 60-day rollover requirement for a taxpayer who completely liquidated an IRA and transferred the proceeds to a non-IRA account. The taxpayer said she misunderstood a tax…
PLR 1331011: IRS waives the 60-day rollover deadline after duplicate IRA payments
The IRS waived the 60-day rollover requirement for a taxpayer who received an unintended duplicate IRA payment during a transfer between financial institutions. The taxpayer relied on a financial…
PLR 1331010: IRS declines waiver for tax withheld from 401(k) and IRA distributions
The IRS declined to waive the 60-day rollover requirement for amounts withheld from a taxpayer's 401(k) and IRA distributions. The taxpayer rolled over the net proceeds but wanted to roll over the…
PLR 1331009: IRS waives the 60-day rollover deadline after a financial institution error
The IRS waived the 60-day rollover requirement for a taxpayer whose financial institution sent an IRA distribution to a non-IRA account despite written rollover instructions. The taxpayer did not…
PLR 1330047: IRS denies rollover waiver because the contribution was timely
An individual received a retirement-plan distribution and asked the IRS to waive the 60-day rollover requirement because of the medical condition and death of the individual's mother. The IRS found…
PLR 1330046: IRS waives the 60-day rollover requirement after a spouse's death
The IRS waived the 60-day rollover requirement for an individual who received a distribution from a deceased spouse's IRA. The taxpayer represented that grief, a medical condition, and related…
CCA addresses deduction and funding treatment of scheduled pension payments
Chief Counsel Advice considers whether payments connected with an acquisition and certain defined benefit pension plans could be deducted or capitalized, and whether they could count toward minimum…
PLR 1330016 approves a direct annuity contract exchange after the owner's death
The IRS rules that a beneficiary may directly transfer the value of five annuity contracts inherited from the beneficiary's mother to a new annuity contract without recognition under IRC §…
PLR 1329030 approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a five-year automatic extension to amortize a plan's unfunded liabilities. The approval covers liabilities described under sections 431(b)(2)(B) and 431(b)(4) of the Internal…
PLR 1329029 approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a five-year automatic extension to amortize a plan's unfunded liabilities. The approval covers liabilities described under sections 431(b)(2)(B) and 431(b)(4) of the Internal…
PLR 1328036: IRS declines to waive the 60-day IRA rollover requirement
The IRS declined to waive the 60-day rollover requirement for two taxpayers who received IRA distributions and did not deposit the amounts into IRAs within the required period. The taxpayers said…
PLR 1327023: IRS waives the 60-day rollover requirement after a medical injury
The IRS waived the 60-day deadline for a taxpayer to roll part of an IRA distribution into another IRA. The taxpayer said a medical injury during the rollover period required home medical care, use…
PLR 1327022: IRS denies a pension minimum funding waiver for lack of temporary hardship
The IRS denied a personal services corporation's request to waive the minimum funding standard for its defined-benefit pension plan. The company had declining revenue, unpaid minimum funding…
PLR 1327021: IRS waives the 60-day rollover requirement after an excess RMD distribution
The IRS waived the 60-day rollover requirement after a financial institution distributed more IRA assets than the taxpayer intended while processing his required minimum distribution. The taxpayer…
PLR 1327020: IRS waives the 60-day rollover requirement after a bank mishandled an IRA transfer
The IRS waived the 60-day rollover deadline after a financial institution transferred an IRA distribution into a taxable joint account instead of a rollover IRA. The taxpayer had intended to keep…
PLR 1325022: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer's husband had dementia during the rollover period, which impaired his ability to remember the…
PLR 1324026: IRS waives the 60-day IRA rollover deadline after a bank error
An IRA owner received a distribution and intended to deposit it into a rollover IRA, but a bank employee placed the funds in a money-market account instead. The mistake was discovered after the…
PLR 1324025: IRS waives rollover deadlines after incorrect financial-institution advice
Two employees received taxable distributions when their employer moved from one retirement plan to another. They intended direct transfers, but taxes were withheld, and a representative of the new…
PLR 1324024: IRS waives an IRA rollover deadline after a decedent's medical incapacity
An executor asked to roll over the remaining portion of IRA distributions received by a decedent. The decedent had completed a partial rollover but did not complete the remainder within 60 days…
PLR 1324023: IRS waives an IRA rollover deadline after medical treatment
An IRA owner withdrew funds to move them to a self-directed IRA but did not complete the rollover within 60 days. The taxpayer's medical conditions and related treatments impaired the ability to…
PLR 1324022: IRS waives an IRA rollover deadline after a fraudulent spousal withdrawal
An individual's spouse withdrew money from the individual's IRA without knowledge or consent, claiming to act under a power of attorney. The spouse used the money for gambling, and the IRA owner…
PLR 1324021: IRS waives an IRA rollover deadline after advisors used a non-IRA account
An IRA owner instructed financial advisors to cash out and reinvest retirement funds, understanding that a rollover had to occur within 60 days. The advisors deposited the distribution into a…
PLR 1323045: IRS treats an IRA transfer as modifying substantially equal payments
The IRS ruled that a partial trustee-to-trustee transfer from one IRA to another modified a series of substantially equal periodic payments. The taxpayer had been receiving payments intended to…
PLR 1323044: IRS waives the 60-day deadline for a retirement-plan rollover
The IRS considered a taxpayer who received a retirement-plan distribution but deposited it into a non-IRA account instead of completing a rollover within 60 days. The taxpayer said severe emotional…
PLR 1323043: IRS approves a church plan and related retiree benefit trust
The IRS considered a church convention's retiree health and life insurance plan and a trust intended to fund its premiums. The IRS ruled that the arrangement was a trust, that the convention would…
PLR 1323042: IRS denies church-plan status for a continuing multi-employer plan
The IRS considered whether a tax-exempt organization's retirement plan qualified as a church plan under IRC § 414(e). The organization was affiliated with a church, but the plan had originally…
PLR 1323041: IRS waives the rollover deadline after fraudulent IRA activity
The IRS considered a taxpayer whose IRA assets were transferred to an entity that falsely represented itself as a qualified IRA custodian. The taxpayer said the custodian's owner engaged in…
PLR 1323040: IRS waives the rollover deadline after incorrect tax advice
The IRS considered a taxpayer who received a distribution from a 403(b) annuity and did not timely roll over part of it after receiving incorrect information from the annuity company. The taxpayer…
CCA explains when section 409A grandfathering rules may apply to a deferred compensation plan
Chief Counsel Advice addresses whether the section 409A transition rules apply to a deferred compensation plan for the open years under review. The advice says the transition rules do not apply and…
PLR 1335028: IRS waives the 60-day retirement-plan rollover deadline after medical injury
An individual received a distribution from an eligible retirement plan and intended to roll it into an IRA within 60 days. A medical injury during the rollover period required hospitalization and…
PLR 1322052: IRS waives the 60-day IRA rollover deadline after a medical misunderstanding
The IRS waived the 60-day deadline for an individual to roll a distribution from an IRA into a rollover IRA. The individual had medical limitations and did not realize that a certificate of deposit…
PLR 1322051: IRS recognizes a private school's pension plan as a church plan
The IRS ruled that a private nonprofit college preparatory school's defined-benefit pension plan qualified as a church plan under section 414(e). The school was associated with a religious order…
PLR 1322050: IRS grants a conditional pension minimum-funding waiver after supplier disruption
The IRS granted a company a conditional waiver of an unpaid required minimum pension contribution for a specified plan year. The company manufactured made-to-order products and experienced temporary…
PLR 1322049: IRS declines to waive the 60-day IRA rollover deadline after funds paid a mortgage
The IRS declined to waive the 60-day deadline for rolling an IRA distribution into an IRA. The taxpayer said that a spouse's final illness and death, together with severe financial hardship, caused…
PLR 1322035: IRS preserves tax treatment for restructured annuity and life-insurance contracts
The IRS ruled on the tax treatment of annuity and life-insurance contracts being restructured as part of an insolvent insurer's liquidation. The restructuring would reduce benefits and replace the…
PLR 1320022: IRS grants more time to recharacterize Roth IRA conversions
An individual asked the IRS for more time to recharacterize two Roth IRA conversions as contributions to traditional IRAs. The individual relied on a tax attorney's advice and later learned that the…
PLR 1320021: Surviving child is the sole designated beneficiary of an IRA held through a trust
The IRS considered an inherited IRA payable to a trust created under a decedent's will. The trust was represented to be valid, irrevocable at death, identifiable as to its beneficiaries, and…
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.