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 1310023: Proposed split-off qualified as a tax-free reorganization
The IRS ruled on a proposed transaction in which a corporation would transfer a wholly owned bank subsidiary, cash, and other assets to a newly formed controlled corporation, then distribute the…
PLR 1310016: Security agreement does not prevent subsidiary from joining its parent's affiliated group
The IRS considered whether a special security agreement designed to limit foreign ownership, control, or influence prevented a subsidiary from being part of its U.S. parent's affiliated group. The…
PLR 1310015: Parent receives more time to file a § 337(d) loss statement
The IRS considered a parent company's request for more time to file a statement needed to elect relief under Treas. Reg. § 1.337(d)-2(c) for a loss on the sale of subsidiary stock. The parent said…
PLR 1310009: Subsidiary treated as having joined its parent's consolidated return
The IRS considered a subsidiary that had been included in its parent's consolidated federal income tax return but had not filed the required Form 1122 or appeared on Form 851. The parent had…
CCA 1309013: IRS explains how section 382 limits recognized built-in losses
Chief Counsel advised that a recognized built-in loss is not treated as a separately determined net operating loss for the year. Instead, the loss is taken into account as a deduction in the annual…
CCA 1308029: Chief Counsel addressed NUBIG and NUBIL computations
Chief Counsel advised that the taxpayer’s position did not alter the net unrealized built-in gain or loss computation under sections 382(h) and 56(g)(4)(G). Instead, it affected how the taxpayer…
CCA 1308026: IRS addresses NUBIG and NUBIL computations after an ownership change
This Chief Counsel Advice addresses whether a taxpayer could exclude certain redacted bank-loan items from the net unrealized built-in gain or loss computation after acquiring a target corporation.…
PLR 1308018: IRS approves a tax-free split-off of an operating business
The IRS ruled on a proposed split-off in which an S corporation would transfer part of its interest in an operating limited liability company to a newly formed S corporation and distribute the new…
PLR 1308017: IRS approves a tax-free split-off of an operating business
The IRS ruled on a proposed split-off in which an S corporation would transfer part of its interest in an operating limited liability company to a newly formed S corporation and distribute the new…
PLR 1308002: IRS approves tax treatment for a complex corporate separation and distribution
The IRS approved the requested federal tax treatment for a large, multi-step restructuring designed to separate one business segment from another and distribute the separated segment through a…
PLR 1308001: IRS approves a recapitalization into tracking-style stock classes
The IRS approved a privately held corporation's plan to replace one class of common stock with voting C stock and voting T stock. The new classes would track different groups of corporate assets,…
PLR 1307001: LLC is treated as joining its parent’s consolidated return
An affiliated group filed a timely consolidated federal income tax return, but one LLC subsidiary had not filed Form 1122 and was not listed on the initial Form 851 because its entity-classification…
PLR 1306014: IRS approves a RIC's cash-or-stock dividend distribution plan
A regulated investment company requested rulings on planned dividends that shareholders could receive in cash or equivalent-value common stock. The plan limited aggregate cash distributions to an…
PLR 1306013: IRS approves a RIC's cash-or-stock dividend distribution plan
A regulated investment company requested rulings on planned dividends that shareholders could receive in cash or equivalent-value common stock. The plan used a dividend reinvestment plan and limited…
PLR 1306012: IRS approves a RIC's cash-or-stock dividend distribution plan
A regulated investment company requested rulings on planned dividends that shareholders could receive in cash or equivalent-value common stock. The plan used a dividend reinvestment plan and limited…
PLR 1306010: IRS approves an S corporation split-off and related reorganization
An S corporation planned to form a wholly owned subsidiary, transfer part of its active business to that subsidiary, and distribute the subsidiary's stock to two shareholders in exchange for their…
PLR 1306008: IRS preserves consolidated-group status after governance changes
A parent corporation and its subsidiary asked whether preferred-stock provisions, a bankruptcy reorganization, a state-law rehabilitation proceeding, and related governance and consent rights would…
PLR 1306007: IRS preserves consolidated-group eligibility under a security proxy arrangement
A foreign parent and its U.S. affiliated group used a proxy arrangement to insulate a subsidiary from foreign ownership, control, or influence while preserving required security clearances. The…
PLR 1306006: IRS approves tax treatment for a series of corporate separations
Several related corporations proposed a series of contributions, internal separations, and an external spin-off. The IRS ruled on the requested federal tax consequences, including nonrecognition of…
PLR 1306003: IRS rules on section 382 limitations after a bankruptcy reorganization
A publicly traded parent company entered Chapter 11 bankruptcy and proposed a reorganization in which its creditors would receive the stock of the reorganized parent. The IRS ruled that the…
PLR 1306001: IRS grants extra time for a consolidated NOL carryback election
A consolidated corporate group failed to timely make an election to carry back a consolidated net operating loss for an extended period under IRC § 172(b)(1)(H). The IRS found that the parent…
PLR 1305010: IRS grants extra time to waive an NOL carryback period
A parent company asked for more time to file an election waiving the entire carryback period for a consolidated group's net operating loss. The election was late because the parent relied on a…
PLR 1305005: IRS grants extra time for an extended NOL carryback election
A parent company asked for more time to elect an extended carryback period for a consolidated group’s net operating loss. The election was not filed on time because the parent relied on a qualified…
PLR 1305003: IRS approves a recapitalization and four related section 355 spin-offs
A corporate group asked the IRS to rule on the federal tax consequences of a planned recapitalization, an internal contribution and spin-off, two additional internal spin-offs, and a final…
PLR 1305001: IRS rules that mutual fund redemptions do not create a section 382 ownership change
An open-end investment company asked about redemptions of its shares by target-date mutual funds that invested in it as part of their asset-allocation strategies. The funds were not formed or…
PLR 1304002: REIT may pay special dividends in cash, stock, or a combination
A REIT planned special dividends after selling properties and realizing taxable gain. Each shareholder could elect all cash, all common stock, or a combination of 20% cash and 80% stock, subject to…
PLR 1301009: IRS grants extra time to elect an extended NOL carryback
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The group missed the filing deadline after relying on a qualified tax…
PLR 1252017: IRS approves a split-off of two controlled corporations from an S corporation
The IRS ruled that a proposed transaction in which an S corporation would contribute assets to two newly formed controlled corporations and distribute their stock to different shareholder groups…
PLR 1252014: IRS approves tax treatment for a multi-step corporate restructuring
The IRS ruled on the tax treatment of a complex restructuring by an affiliated group that wanted to separate two businesses. The proposed steps included entity conversions, a subsidiary merger,…
PLR 1252012: IRS approves cash-or-stock distributions by a prospective REIT
The IRS ruled that a publicly traded corporation planning to elect REIT status could make special distributions in which shareholders chose cash or common stock. The cash available for each…
PLR 1252011: IRS approves tax treatment for a cross-border acquisition and reorganization
The IRS ruled on the tax consequences of a transaction involving a publicly traded foreign target, a cross-border amalgamation, and a series of acquisitions and redemptions. The ruling treated the…
PLR 1252008: IRS ruled on stock sales, distributions, and a planned corporate liquidation
The IRS ruled on a series of completed and proposed transactions among a parent company and foreign and domestic subsidiaries. The ruling addressed the tax treatment of cross-chain stock sales, a…
PLR 1252006: IRS granted late-election relief to reattribute a subsidiary's tax attributes
The IRS granted a consolidated group an extension of time to make an election reattributing a subsidiary's net operating loss carryover to the parent. The election followed a stock sale that…
PLR 1252002: IRS approved specified cross-border corporate reorganizations
The IRS approved specified federal income tax treatment for a multinational group's completed and proposed reorganizations. The ruling covered transfers of stock and assets among related…
PLR 1251008: IRS grants extra time to file a consolidated return election
The IRS granted a corporate parent and members of its affiliated group 45 days to make a consolidated return election for a short taxable year. The group missed the regulatory deadline after the…
PLR 1251006: IRS approves a proposed tax-free corporate separation
The IRS ruled on a proposed transaction in which a corporation would transfer one business to a newly formed controlled corporation and distribute that corporation's stock through an internal and…
PLR 1251003: IRS addresses a subsidiary's departure from a consolidated group
The IRS ruled on a proposed transaction involving a privately held parent and several domestic and foreign subsidiaries. The parent would acquire additional stock of a subsidiary and transfer that…
PLR 1251002: IRS addresses capital contributions in a section 382 ownership change
The IRS ruled that certain capital contributions made before a corporation's ownership change would not be treated as contributions made under a plan whose principal purpose was to avoid or increase…
PLR 1250021: IRS approves supplemental stock-for-stock reorganization rulings
The IRS issued supplemental rulings for a proposed acquisition in which Target shareholders would exchange their stock solely for voting stock of Controlled 11. The ruling addressed related debt…
PLR 1250017: IRS rules that a subsidiary must file a separate return
The IRS ruled that a subsidiary had to file a separate federal income tax return for a specified tax year. The subsidiary had previously joined its parent's consolidated returns, but it later became…
PLR 1250010: IRS grants extra time for a worthless stock loss election
The IRS granted a corporate parent an additional 75 days to file a statement required to elect recognition of a loss on the disposition of subsidiary stock under Treas. Reg. § 1.337(d)-2(c). The…
PLR 1250004: IRS approves cross-border F and D reorganizations in an acquisition structure
The IRS approved the federal tax treatment of a proposed cross-border acquisition and restructuring involving a domestic parent, a foreign corporation, a new foreign acquirer, and multiple foreign…
PLR 1250002: IRS grants extra time to elect an extended NOL carryback
The IRS granted a consolidated group 60 days to file an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline while relying on a…
PLR 1249012: IRS modifies a corporate separation ruling
The IRS supplemented an earlier private letter ruling on a series of corporate separations, reorganizations, distributions, and related transactions. The supplemental ruling changed which affiliated…
PLR 1249011: IRS approves a stock acquisition after a corporate spin-off
The IRS supplemented an earlier private letter ruling involving a corporate separation followed by an acquisition of a target company. The planned acquisition used a merger subsidiary, with target…
PLR 1249010: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated corporate group an extension of time to make an election for an extended carryback period for a consolidated net operating loss. The election had not been timely…
PLR 1249005: IRS grants more time to claim a worthless stock loss election
The IRS granted a consolidated group an extension of time to file statements needed to claim a worthless stock loss election for two subsidiaries. The subsidiaries' stock became worthless, but the…
PLR 1249004: IRS grants more time for an extended net operating loss carryback election
The IRS granted a consolidated group 60 more days to make an election for an extended carryback period for a consolidated net operating loss. The group missed the deadline for the election, which…
PLR 1248012: IRS grants more time for CNOL carryback elections
The IRS granted a consolidated group more time to revoke an election waiving a net operating loss carryback and to elect an extended carryback period. The group missed the deadline after relying on…
PLR 1248002: IRS approves revocation of a section 1504(d) election and related reorganization treatment
The IRS consented to a parent corporation's revocation of an election that treated a wholly owned corporation formed under contiguous-country law as domestic for federal tax purposes. The revocation…
CCA 1247010: IRS advises that escrow-funded litigation payments are deductible and do not redeem stock
The IRS Office of Chief Counsel considered a corporate restructuring in which a parent company placed funds in escrow to pay litigation liabilities connected with a subsidiary and certain former…
PLR 1247009: IRS approves a tax-free reorganization merging two regulated investment companies
The IRS ruled on a proposed reorganization in which one regulated investment company would transfer all of its assets and stated liabilities to another regulated investment company in exchange for…
PLR 1247005: IRS grants more time to elect an extended net operating loss carryback
The IRS granted a consolidated group 60 additional days to make an election extending the carryback period for a consolidated net operating loss. The group had failed to timely file the election…
PLR 1247004: IRS treats a cash-or-stock distribution and related debt adjustment as taxable distributions
The IRS ruled on a corporation's planned distribution in which shareholders could elect to receive cash or stock, subject to a cap on the total cash paid. The corporation expected to elect to be…
PLR 1247001: IRS approves a tax-free split-off to resolve shareholder disputes
The IRS ruled on a proposed split-off designed to resolve disputes between two shareholders of an S corporation. The corporation would transfer selected business assets and related liabilities to a…
PLR 1246027: IRS grants nonrecognition rulings for a corporate spin-off and split-off
The IRS issued favorable rulings for a corporate separation that included a spin-off of a controlled subsidiary to its parent and a split-off of the same subsidiary to a shareholder in exchange for…
PLR 1246021: IRS grants more time for a section 338(g) election
The IRS granted a purchaser 45 days to file a late IRC § 338(g) election for the stock of four controlled foreign corporations. The purchaser acquired the stock through disregarded entities but…
PLR 1245020: IRS approves a split-off of a controlled corporation
The IRS ruled on a proposed transaction in which a holding company would transfer property rights to a controlled subsidiary, exchange shares with certain shareholders, and distribute all of the…
PLR 1245009: IRS grants extra time to make an extended CNOL 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 not timely filed the election because it…
PLR 1244008: IRS approves tax treatment for a two-stage corporate spin-off
A parent company planned to separate one business from another through an internal distribution followed by a pro rata distribution of the controlled company's stock to the public shareholders. 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.