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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Determination 1319037: IRS approves a five-year amortization extension for an employee benefit plan
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of an employee benefit plan. The approval applied to the eligible amortization charge bases…
PLR 1319036: IRS recognizes a hospital retirement plan as a church plan
Two tax-exempt hospitals asked whether their defined contribution profit-sharing plan qualified as a church plan. The hospitals were controlled or associated with a church through a religious order…
PLR 1319035: IRS approves a conditional minimum funding waiver
The IRS approved a waiver of a plan's required minimum funding contribution for a specified plan year. The approval was conditional on the sponsor making later contributions, timely quarterly…
PLR 1319034: IRS waives the 60-day IRA rollover deadline after a bank error
An individual asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The individual intended to transfer the distribution into a rollover IRA, but a bank…
PLR 1318033: Inherited IRA interests may be divided into four sub-IRAs
An estate inherited an individual retirement account after the account owner died without naming a beneficiary. The estate administrator planned to divide the account into four equal inherited…
PLR 1318032: 60-day rollover deadline waived after misleading advice
An IRA owner received a distribution and missed the 60-day rollover deadline after relying on an advisor's incorrect information. Part of the money was sent to an escrow agent and used to buy stock…
PLR 1318031: Rollover deadline waived after a financial institution mishandled instructions
An employee took a distribution from a former employer's 401(k) plan and instructed the plan administrator to roll most of the account into an IRA. The financial institution instead transferred only…
PLR 1318030: Three retirement plans qualify as church plans
The IRS considered whether a nonprofit hospital's defined benefit, money purchase, and tax-deferred annuity plans qualified as church plans under IRC § 414(e). The hospital was controlled by a…
PLR 1318029: Rollover deadline waived after a custodian opened the wrong account
An IRA owner intended to move retirement funds into a savings account within his IRA after a certificate of deposit matured. The custodian instead opened a non-IRA savings account, creating an…
PLR 1317026: Multiemployer plan receives five-year funding amortization extension
A multiemployer plan requested a five-year automatic extension for amortizing specified unfunded liabilities. The IRS approved the request under section 431(d)(1) after the plan submitted the…
PLR 1317025: Government employer may pick up mandatory retirement contributions
A municipality asked whether it could pick up mandatory employee contributions to a defined benefit governmental plan under section 414(h). The IRS concluded that the contributions qualify whether…
PLR 1317024: IRS waives the 60-day IRA rollover deadline
An individual received a distribution from an individual retirement annuity but missed the 60-day rollover deadline after relying on misleading information and errors by an insurance representative.…
PLR 1317023: IRS waives rollover deadline after mistaken tax withholding
A surviving spouse intended to transfer inherited IRA funds directly from one IRA to another. The financial institution mistakenly withheld an amount for federal income taxes even though the…
PLR 1317022: IRS waives rollover deadline after IRA funds were misdirected
An individual asked to change investments within an IRA, but a financial institution transferred the funds out of the IRA into a non-qualified account instead. The individual did not request a…
PLR 1317021: IRS declines to waive rollover deadline after medical-expense withdrawal
An individual withdrew money from an individual retirement annuity to pay medical expenses and insurance premiums during the individual's spouse's serious illness. The taxpayer later learned about…
PLR 1316028: IRS declines to waive the 60-day IRA rollover deadline
An individual received a distribution from an IRA and transferred it to a non-IRA account during divorce proceedings. She did not realize until the following year that the amount should have been…
PLR 1316027: IRS waives the 60-day IRA rollover deadline after a bank error
An individual requested a distribution from an IRA intending to roll it into another IRA. A bank representative instead prepared paperwork for a non-IRA certificate of deposit, and the individual…
PLR 1316026: IRS declines to waive rollover deadlines for two taxpayers
Two taxpayers transferred distributions from their separate IRAs to non-IRA accounts at the same company to increase their trading power for stock options. They later argued that they did not…
IRS denies minimum-funding waiver for financially distressed academic institution
The IRS denied a nonprofit academic institution’s request for a waiver of the minimum funding standard for its pension plan. The institution reported permanent financial distress, including…
PLR 1316024: IRS declines to waive rollover deadline after escrow use
An individual withdrew funds from an IRA and placed them in a non-IRA escrow account to help a daughter qualify to purchase a foreclosed home. The taxpayer intended to return the funds to an IRA…
PLR 1315036: IRS waives the 60-day IRA rollover deadline
The IRS granted a waiver of the 60-day rollover requirement for an IRA distribution. The taxpayer completed the rollover late after medical conditions impaired her ability to manage financial…
PLR 1315035: IRS waives the 60-day rollover deadline after a spouse's death
The IRS granted a waiver of the 60-day rollover requirement for a surviving spouse's distribution from a qualified retirement plan. The taxpayer delayed the rollover while dealing with emotional…
PLR 1315034: IRS waives the 60-day IRA rollover deadline after erroneous advice
The IRS waived the 60-day rollover requirement for an IRA distribution after the taxpayer relied on erroneous information from an investment-service representative. The taxpayer believed the amount…
PLR 1314057: IRS waives 60-day IRA rollover deadline after financial-institution error
The IRS considered an elderly taxpayer's missed rollovers from two individual retirement accounts. The taxpayer relied on financial-institution personnel to transfer the distributed amounts, but the…
PLR 1314056: IRS waives rollover deadline after erroneous IRA custodian advice
The IRS considered a taxpayer who transferred an IRA distribution into an account that was not a qualified rollover IRA because the receiving company was not an approved non-bank IRA trustee or…
PLR 1314055: IRS waives the 60-day IRA rollover deadline after a taxpayer's bereavement-related mental impairment
An individual received a distribution from a deceased spouse's IRA but did not complete the rollover within 60 days. The individual represented that anxiety and stress following the spouse's death…
PLR 1314054: IRS grants extra time after a financial institution mishandles an IRA rollover
An individual received a check from an IRA and delivered it to a broker with instructions to establish a rollover IRA. The broker instead deposited the funds into a non-IRA brokerage account and…
PLR 1314053: IRS waives an IRA rollover deadline after the account owner's serious illness and death
An IRA owner received a distribution and deposited it into a checking account, intending to complete a rollover. During the 60-day period, his health rapidly declined because of a brain disorder…
PLR 1314052: IRS waives an IRA rollover deadline after a custodian misclassified an investment
An individual directed an IRA custodian to make a private-placement investment for the IRA. The custodian approved the investment process, but later treated the investment as a taxable distribution…
PLR 1314051: IRS waives an IRA rollover deadline after a custodian misclassified an investment
An individual directed an IRA custodian to make a private-placement investment for the IRA. The custodian approved the investment process, but later treated the investment as a taxable distribution…
PLR 1314050: IRS waives an IRA rollover deadline after erroneous advice about an IRA custodian
An individual transferred funds from an IRA to a company after relying on advice that the company could accept the rollover. The company was not an approved non-bank trustee, so the funds were…
CCA 1313027: IRS maintains income exclusion position and identifies possible mitigation relief
The IRS advised that it continued to oppose a taxpayer's request to exclude a redacted amount from income for a redacted year. The memo also analyzed the mitigation provisions in IRC §§ 1311 through…
CCA 1313025: IRS analyzes tax from an erroneous qualified-plan overpayment and rollover
The IRS analyzed a taxpayer who received an overpayment from a qualified employer plan, rolled the overpayment into an IRA based on an erroneous Form 1099-R, and later withdrew it. The memo…
PLR 1311045: IRS approves a five-year automatic amortization extension for a multiemployer plan
The IRS approved a five-year automatic extension for a multiemployer plan to amortize unfunded liabilities. The extension applies to the eligible amortization charge base identified in the request.…
PLR 1311044: IRS approves a five-year automatic amortization extension for a multiemployer plan
The IRS approved a five-year automatic extension for a multiemployer plan to amortize unfunded liabilities. The extension applies to eligible amortization charge bases identified in the application.…
PLR 1311043: IRS waives the 60-day rollover deadline after misleading tax advice
The IRS waived the 60-day rollover requirement for an elderly taxpayer who moved an IRA distribution into a non-IRA trust account after receiving misleading advice from a CPA and financial adviser.…
PLR 1311042: IRS waives the 60-day rollover deadline after a plan failed to explain rollover rights
The IRS waived the 60-day rollover requirement for a surviving spouse who received a lump-sum distribution from an employer plan. The IRS found that the plan sponsor’s failure to explain the…
PLR 1311041: IRS waives the 60-day rollover deadline after checks were mailed to the wrong address
The IRS waived the 60-day rollover requirement for a taxpayer whose plan distribution checks were mailed to an incorrect address by a financial institution. The taxpayer retrieved the checks shortly…
PLR 1311040: IRS approves a conditional waiver of a pension plan's minimum funding contribution
The IRS approved a conditional waiver of a plan’s required minimum funding contribution for the plan year ending December 31, 2011. The waiver covered the remaining unpaid contribution and required…
PLR 1311039: IRS waives the 60-day rollover deadline after a financial institution distributed the wrong assets
The IRS waived the 60-day rollover requirement after a financial institution mistakenly transferred shares instead of the requested cash amount from an IRA. The taxpayer did not discover the error…
PLR 1311038: IRS waives the 60-day rollover deadline for a taxpayer with a disabling mental condition
The IRS waived the 60-day rollover requirement for a taxpayer whose mental condition impaired the ability to make financial decisions during the rollover period. The taxpayer represented that the…
PLR 1311037: IRS waives rollover deadlines for a married couple affected by a mental condition
The IRS waived the 60-day rollover requirement for three IRA distributions received by a married couple. The wife’s mental condition impaired her ability to make financial decisions, and the couple…
PLR 1310052: IRS waives the 60-day rollover deadline after a financial institution error
The IRS granted a taxpayer a waiver of the 60-day deadline for rolling an IRA distribution into a rollover IRA. The taxpayer received a duplicate required minimum distribution because of an error by…
IRS grants a five-year amortization extension for a multiemployer plan
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a multiemployer plan. The extension applied to eligible amortization charge bases…
PLR 1310050: IRS waives the 60-day rollover deadline after a broker misdirects IRA funds
The IRS waived the 60-day deadline for an IRA rollover after a broker deposited the distribution into a non-IRA brokerage account instead of opening the requested rollover IRA. The taxpayer had…
PLR 1309028: IRS recognizes three retirement plans as church plans
The IRS considered three retirement plans sponsored by a tax-exempt corporation controlled by an association of churches. The corporation operated senior housing and related religious services, and…
PLR 1309027: IRS waives the 60-day IRA rollover deadline after illness and a financial institution error
The IRS considered a taxpayer who received a distribution from an IRA but did not complete the rollover within 60 days. The taxpayer had instructed one financial institution to transfer the funds to…
PLR 1309026: IRS waives the 60-day IRA rollover deadline after an unauthorized distribution
The IRS considered a taxpayer whose IRA custodian caused a distribution that she had not requested. She did not learn about the distribution until after the 60-day rollover period had expired, and…
PLR 1309025: IRS waives the 60-day IRA rollover deadline after incorrect financial advice
The IRS considered a taxpayer who withdrew money from an IRA to fund a residence purchase after a financial adviser gave an incorrect rollover deadline. The taxpayer redeposited the amount after the…
PLR 1309024: IRS waives the 60-day IRA rollover deadline after a bank error
The IRS considered a taxpayer who withdrew IRA assets intending to roll part of them into another IRA certificate of deposit and use the remainder for living and medical expenses. A bank employee…
PLR 1309023: IRS declines a 60-day IRA rollover waiver when the taxpayers had notice of the deadline
The IRS considered two taxpayers who received distributions from separate IRAs and used the funds for household and tax expenses. They requested waivers of the 60-day rollover requirement, saying…
PLR 1309022: IRS waives the 60-day IRA rollover deadline after a divorce-related transfer error
The IRS considered a taxpayer who received an IRA distribution after a divorce-related transfer was mishandled by a financial institution. The taxpayer had instructed the institution to treat the…
PLR 1309021: IRS waives the 60-day IRA rollover deadline after an adviser failed to establish the receiving IRA
The IRS considered a taxpayer who withdrew money from an IRA to roll it into a new IRA and invest through that account. The taxpayer sent the money to a financial adviser, who was supposed to…
PLR 1309020: Missed and make-up IRA payments do not disrupt substantially equal payments
The IRS considered a taxpayer receiving substantially equal periodic payments from an IRA under the fixed amortization method. The IRA custodian missed one scheduled annual payment because the…
PLR 1308037: IRS waived the 60-day rollover deadline for part of a pension distribution
The IRS considered a taxpayer's request to roll part of a pension distribution into an IRA after the 60-day deadline. The plan had not provided the written rollover notice required by section…
Determination 1308036: IRS approved a five-year amortization extension for a pension plan
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval was based on the plan's submission of the information and…
PLR 1308035: IRS waived the 60-day IRA rollover deadline after a financial institution error
The IRS considered an IRA distribution that was intended to be rolled into a new IRA but was placed into an account with the wrong ownership. The taxpayer represented that the distribution had not…
PLR 1308034: IRS waived the 60-day IRA rollover deadline after misleading account instructions
The IRS considered an IRA distribution that the taxpayer intended to divide between two new IRAs. Representatives directed the taxpayer to online forms but did not explain the difference between IRA…
PLR 1308033: IRS ruled that a religious employer’s retirement plan was a church plan
The IRS considered a retirement plan maintained by a religious educational employer. The plan was administered by a committee connected to the employer’s governing structure and affiliated with a…
PLR 1306033: IRS waives the 60-day IRA rollover deadline after adviser fraud
The IRS considered a taxpayer and spouse who withdrew amounts from two IRAs intending to roll them into new IRAs within 60 days. An investment adviser falsely represented that the rollovers had been…
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.