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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Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included study…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included study…
Public high school scholarship procedures receive approval
A private foundation sought approval for renewable scholarships benefiting graduating seniors at a public high school. The school principal would recommend students without a separate application, and…
County scholarship procedures receive advance approval
A private foundation sought approval for scholarships supporting post-high-school education for students from a county high school, with possible expansion to other schools and home-schooled students.…
Employer-related scholarship procedures receive approval
A private foundation sought approval for scholarships serving eligible children of a company's employees and eligible full-time students who were themselves employees. Awards could support college, sp…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included study…
Law student scholarship procedures receive advance approval
A private foundation sought advance approval for scholarships benefiting senior law students in one state. A state agency publicized the program, ranked applicants using academic promise and financial…
Employer scholarship procedures receive advance approval
A private foundation sought advance approval for scholarships serving eligible dependent children of a company's employees. Applicants had to satisfy employment, household-income, and enrollment condi…
Local college and technical scholarships receive approval
A private foundation sought advance approval for nonrenewable scholarships for local students entering at least their second year of college or technical school. Eligibility required residence in the …
Regional scholarships receive advance approval
A private foundation sought advance approval for scholarships helping graduating seniors from named counties attend college or a post-high-school trade or technical school. Applicants had to live in t…
Beverage-industry family scholarships receive approval
A private foundation sought advance approval for scholarships for graduating high school students whose parent worked full time in the alcohol beverage industry. Applicants had to attend school in the…
Entrepreneurship scholarships receive advance approval
A private foundation sought advance approval for scholarships for school-district seniors who showed entrepreneurial drive and planned higher education within the named state. Applicants submitted an …
In-state undergraduate scholarships receive approval
A private foundation sought advance approval for need-based undergraduate scholarships for graduates of public high schools in three named cities. Recipients had to attend an accredited Protestant or …
County graduate scholarships receive advance approval
A private foundation sought advance approval for scholarships based on financial need for graduates of high schools in a named county. The program considered student ability, extracurricular activitie…
State college scholarship procedures receive approval
A private foundation sought advance approval for scholarships for high school seniors attending approved four-year colleges and universities within a named state. Eligibility covered citizens or perma…
Catholic school scholarships receive advance approval
A private foundation sought advance approval for scholarships covering tuition and books at Catholic primary and secondary schools in a named area. Applicants needed financial assistance and at least …
County resident scholarships receive advance approval
A private foundation sought advance approval for scholarships for residents of a named county and state who selected their own college or university. The trust agreement considered character, above-av…
Business league exemption revoked for inadequate records
An organization recognized under section 501(c)(6) described itself as a membership group offering educational meetings and seminars for chief executives and entrepreneurs. During examination, it coul…
Inactive educational organization faced revocation
A section 501(c)(3) organization had operated a community program intended to prevent juvenile crime and promote citizenship. Its board later dissolved the organization and donated the remaining funds…
Disaster-business marketplace denied charitable exemption
A nonprofit applied for section 501(c)(3) status to operate an online marketplace connecting consumers with registered small businesses after disasters. Most revenue would come from annual registratio…
Delay does not excuse surrender of property subject to levy
Chief Counsel addressed whether a levied party still had to comply after time passed before it identified property reached by the levy. If the party possessed the property, or was obligated with respe…
Domestic re-adoption is not required for adoption credit
Chief Counsel addressed an examination that disallowed an adoption tax credit because a non-Hague foreign adoption was not followed by a U.S. re-adoption. Revenue Procedure 2005-31 allows a taxpayer w…
Partnership-level examination required for barred-year NOL item
Chief Counsel addressed a partner's net operating loss carryforward that arose from a TEFRA partnership or affected item in an earlier year. Although the assessment limitations period had expired for …
Reviewed trust met domestic court and control tests
Chief Counsel analyzed whether a trust was a United States person under the court and control tests. The trust instrument placed administration with a U.S. trustee and contained no automatic migration…
Representative may receive information but not attend witness interview
Chief Counsel explained that sections 6103(e)(6) and (e)(7) permit the IRS to disclose a taxpayer's return information to a properly designated legal representative when the disclosure falls within th…
Refund result depends on when amended return was filed
Chief Counsel compared payments accompanying amended returns filed before and after the assessment limitations deadline. A payment with a return filed after that deadline is a statutory overpayment un…
Prior-year resolution may support TEFRA disclosure
Chief Counsel explained that each tax year is a separate cause of action. When the partners differ, the IRS generally requires a separate final partnership administrative adjustment for each year to a…
Authorized corporate officer must sign power of attorney
Chief Counsel agreed that a power of attorney must be executed by someone with authority to legally bind the taxpayer. For a corporation, an authorized officer must sign and certify that authority, co…
AOTC refundability depends on claimant's child status
Chief Counsel addressed when the refundable portion of the American Opportunity Tax Credit is unavailable under the child-status rules. The credit may cover qualified education expenses of the taxpaye…
Truck service facilities require 39-year depreciation
A partnership claimed 15-year depreciation for facilities leased to a related truck dealer that sold and leased trucks, sold parts, and performed maintenance and repairs. The properties sold oil, lubr…
Partnership may make retroactive QEF election
A domestic partnership owned an interest in a foreign corporation whose only asset was stock in another foreign company. An initial public offering reduced the first corporation's ownership enough to …
Move between countries supported foreign income reelection
A taxpayer had elected the section 911 foreign earned income exclusion and later revoked that election. Within five years, the taxpayer's employer moved him from one foreign country to another with a …
LLC receives late corporate and S elections
A single-member LLC intended to be treated as an S corporation from a specified date, but timely filed neither Form 8832 nor Form 2553. The LLC represented that it acted reasonably and in good faith, …
Estate receives 45 days to make late debt election
A deceased taxpayer had owned an interest in a partnership whose commercial-property debt was reduced. The partnership and its adviser intended the partners to elect the qualified real property busine…
Partner receives 45 days to make late debt election
An individual partner held an interest in a partnership whose commercial-property debt was reduced. The partnership and its adviser intended the partners to elect the qualified real property business …
Partner receives 45 days to make late debt election
An individual partner held an interest in a partnership whose commercial-property debt was reduced. The partnership and its adviser intended the partners to elect the qualified real property business …
Partner receives 45 days to make late debt election
An individual partner held an interest in a partnership whose commercial-property debt was reduced. The partnership and its adviser intended the partners to elect the qualified real property business …
Trust receives 45 days to make late debt election
A trust partner held an interest in a partnership whose commercial-property debt was reduced. The partnership and its adviser intended the partners to elect the qualified real property business indebt…
Grantor trust receives 45 days to make late debt election
A grantor trust held an interest in a partnership whose commercial-property debt was reduced, with the grantor reporting the trust's tax items. The partnership and its adviser intended the partners to…
Senior communities qualify as congregate care facilities
A real estate investment trust owned age-restricted independent-living communities that offered meals, housekeeping, transportation, security, mobility features, wellness monitoring, emergency support…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary. T…
Municipal utility cooperative's income remains excluded under section 115
A state nonprofit cooperative owned by political subdivisions asked the IRS to modify and supersede an earlier ruling about its federal tax treatment. The cooperative pooled resources to procure utili…
IRS waives IRA rollover deadline after erroneous financial advice
An IRA owner received several checks while closing an account for a rollover, but a financial advisor incorrectly said the process would take two to three months. The owner held the checks until the f…
Religious studies scholarship procedures receive approval
A private foundation requested advance approval for scholarships supporting students engaged in religious studies at seminaries or accredited colleges and universities. Eligible applicants included up…
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.