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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 1244006: IRS approves tax treatment for three related corporate distributions
A foreign parent planned to separate several businesses through deemed contributions and three related stock distributions involving two distributing companies and two controlled companies. The…
CCA 1243014: Chief Counsel advises on consolidated net operating loss carrybacks
Chief Counsel reviewed advice about an unclaimed consolidated net operating loss carryback and agreed that the identified consolidated net operating loss should not be included in calculating…
CCA 1243013: Chief Counsel analyzes netting of intercompany asset sales
Chief Counsel analyzed whether allocating the total price from an intercompany sale equally among assets with different values and useful lives could distort a consolidated group's depreciation…
PLR 1242010: IRS grants more time for a consolidated 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 group had intended to make the…
PLR 1242008: IRS grants a 60-day extension for a consolidated NOL election
The IRS granted a consolidated corporate group 60 days from the ruling date to make an election for an extended carryback period for a consolidated net operating loss. The group did not file a valid…
PLR 1242007: IRS approves a § 351 contribution followed by public offerings
The IRS approved a proposed transaction in which a partnership would transfer the assets and liabilities of a business group to a newly formed corporation in exchange for two classes of stock,…
PLR 1240017: IRS approves tax treatment for a multinational corporate separation
A multinational corporate group asked the IRS to rule on the federal income tax consequences of a long series of proposed mergers, liquidations, asset contributions, stock distributions, spin-offs,…
PLR 1240016: IRS approves a split-off of two new corporations from an S corporation
An S corporation asked whether it could form two new corporations, transfer parts of its business assets to them, and distribute each new corporation's stock to specified shareholders in exchange…
PLR 1240013: IRS approves a divisive reorganization of an S corporation's businesses
An S corporation asked whether it could separate three business lines into two newly formed S corporations, then distribute the new corporations' stock to two shareholders while making a cash…
PLR 1239003: IRS approves two type F reorganizations before an asset sale
A domestic parent asked the IRS to approve a restructuring involving a domestic subsidiary, a foreign subsidiary, and two newly formed foreign companies. In the first reorganization, the existing…
PLR 1238018: IRS approves a tax-free split-off and related S corporation reorganization
The IRS approved a proposed transaction in which an S corporation would transfer about half of its assets to a wholly owned QSub, distribute the QSub stock to one shareholder in exchange for that…
CCA 1237017: CCA addresses liabilities in an S corporation liquidation
Chief Counsel advice considered an S corporation that distributed assets subject to liabilities in a complete liquidation. The advice concluded that the liabilities are considered in calculating the…
PLR 1237012: IRS approves an accounting-method change for service liabilities
The IRS approved an accounting-method change for a corporation that acquired a subsidiary in a section 381 transaction. The parent and subsidiary had used different methods for deducting liabilities…
PLR 1237010: IRS grants late extended carryback election relief
The IRS granted a consolidated group 60 days to file a late election for an extended carryback period for a consolidated net operating loss. The group had intended to make the election under section…
CCA 1236025: Advice treats participating convertible preferred stock as common stock
Chief Counsel advice addressed whether voting convertible preferred stock should be treated as common stock when analyzing a redemption under IRC § 302(b)(2). The advice concludes that the stock…
PLR 1236015: IRS grants extra time to make an extended NOL carryback election
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 missed the election deadline while relying on a…
PLR 1236014: IRS approves a spin-off and related corporate reorganizations
A public company proposed a series of mergers, entity conversions, liquidations, asset contributions, and a spin-off to separate two business lines from a third. The IRS ruled that specified steps…
Extension granted for consolidated NOL carryback election
A consolidated corporate group requested more time to elect an extended carryback period for a consolidated net operating loss. The group intended to make the election but failed to file a valid…
Extension granted for a late ratable allocation election
An affiliated group and a subsidiary asked for more time to make a ratable allocation election after the subsidiary left the consolidated group. The IRS concluded that the taxpayers acted reasonably…
IRS grants extra time to make an extended NOL carryback election
The IRS granted a consolidated corporate group 60 additional days to make an election for an extended net operating loss carryback period. The group had failed to timely file the election after…
IRS grants extra time for an extended consolidated NOL carryback election
The IRS granted a consolidated group 60 days to make an election under section 172(b)(1)(H) to carry back a consolidated net operating loss for three, four, or five years instead of the usual…
IRS approves tax-free split-offs of two businesses
The IRS approved a proposed transaction in which an S corporation would contribute portions of its business assets to two newly formed corporations and distribute the stock of each new corporation…
PLR 1233016: IRS approves a three-stage corporate separation under the tax-free reorganization rules
The IRS ruled on a proposed series of transactions separating one business from two other business lines within a multinational corporate group. The plan used contributions of assets and stock…
PLR 1233006: IRS grants more time for an extended net operating loss 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 group intended to make the…
PLR 1232033: IRS approves a complex corporate separation and reorganization
A publicly traded holding company proposed a series of contributions, distributions, redemptions, mergers, and spin-offs to separate two businesses across a large affiliated group. The IRS issued…
PLR 1232030: IRS approves privatization transfer of a government insurance fund
A government-established insurance fund planned to transfer its insurance business and subsidiaries to a new mutual insurer as part of a state-law privatization. The new insurer would issue…
PLR 1232017: IRS grants more time to restore value under the controlled-group loss rules
A parent corporation and certain subsidiaries were members of a controlled group when the parent underwent an ownership change. The group had failed to timely elect under the regulations to restore…
PLR 1232016: IRS grants more time to restore value under the controlled-group loss rules
A parent corporation and certain subsidiaries were members of a controlled group when the parent underwent an ownership change. The group had failed to timely elect under the regulations to restore…
PLR 1232015: IRS treats omitted subsidiaries as joining a consolidated return
A parent corporation filed an initial consolidated federal income tax return that included several subsidiaries, but the subsidiaries did not timely file the required Forms 1122. The parent…
PLR 1232014: IRS approves tax treatment for a corporate spin-off and related reorganization
A publicly traded corporation planned to separate two businesses by transferring one business to a controlled corporation and distributing the controlled corporation's stock to the parent's…
PLR 1232011: IRS rules on built-in loss limits after a REIT election is revoked
A corporation elected REIT status, causing certain wholly owned affiliates to become qualified REIT subsidiaries. After the corporation revoked its REIT election, those subsidiaries were treated as…
PLR 1230020: IRS permits a transfer between bankruptcy liquidating trusts
The IRS issued a supplemental ruling for a corporation liquidating through several trusts after a bankruptcy-related dispute over asset proceeds. A court order allowed Trust C to sell stock and…
PLR 1230008: IRS issues supplemental rulings on liabilities and warrants in a corporate separation
The IRS issued supplemental rulings for a tax-free corporate separation in which a business was contributed to a controlled corporation and the controlled corporation’s stock was distributed to the…
PLR 1230007: IRS approves a tax-free corporate split-off
The IRS ruled that a completed transaction qualified as a tax-free corporate separation under IRC §§ 368(a)(1)(D) and 355. The distributing corporation transferred one business to a newly formed…
PLR 1230005: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to elect an extended carryback period for a consolidated net operating loss. The group missed the deadline because it relied on a…
PLR 1230004: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent intended to make the election but…
PLR 1230003: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent missed the deadline after relying…
PLR 1229004: IRS confirms treatment of a proposed ownership-change transaction under § 382
The IRS issued a supplemental ruling concerning a company’s proposed public offering, debt restructuring, and redemption transaction. The company asked whether the proposed transaction would affect…
PLR 1229002: IRS approves a foreign-company spin-off and related restructuring
A taxpayer proposed to separate two businesses through a spin-off involving foreign corporations, disregarded entities, and several subsidiaries. The IRS ruled that the contribution of assets to…
PLR 1229001: IRS grants extra time to waive a consolidated NOL carryback
The IRS granted a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group had intended to make the election…
IRS treats a refinancing transaction as separate from an earlier restructuring
The IRS issued a supplemental private letter ruling concerning a refinancing involving affiliated entities, stock sales, a stock distribution, and debt restructuring. It ruled that the later…
PLR 1228033: Corporate separation and merger planned for tax-free treatment
A corporate group asked the IRS about a proposed separation of two business lines, followed by a merger of one separated business with an unrelated public company. The plan included converting three…
PLR 1228030: IRS approves a complex corporate separation and spin-off plan
A multinational corporate group asked about a complex restructuring that would separate transferred businesses from retained businesses. The plan included multiple subsidiary liquidations and…
PLR 1228023: IRS permits an extended bankruptcy liquidation period and delays cancellation-of-debt income
A corporate group in Chapter 11 bankruptcy asked whether its wind-down plan would continue to qualify as a plan of liquidation for federal income tax purposes. The IRS ruled that the plan could…
PLR 1228012: IRS approves a family succession redemption with installment treatment
A corporation's sole shareholder planned to give stock to two children and then have the corporation redeem the shareholder's remaining shares for cash and a promissory note. The IRS ruled that the…
PLR 1228011: IRS approves a qualified stock purchase and related corporate separation steps
A publicly traded corporate group planned to separate a business through a newly formed corporation, an exchange of target stock for Newco stock, public and private sales of Newco stock, and later…
PLR 1228008: IRS grants more time for a consolidated NOL carryback election
A consolidated corporate group missed the election to carry back a consolidated net operating loss for an extended period under IRC § 172(b)(1)(H). The IRS found that the group acted reasonably and…
PLR 1228007: IRS grants a consolidated group more time to make an extended 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. The IRS found that the group acted reasonably and in good…
PLR 1228005: IRS grants more time to waive the carryback period for a consolidated NOL
A corporation that became part of another consolidated group failed to timely elect to waive the entire carryback period for a consolidated net operating loss. The IRS found that the former common…
PLR 1228004: IRS grants a consolidated group more time to make an extended 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. The IRS found that the group acted reasonably and in good…
PLR 1228002: IRS approves tax treatment for a corporate spin-off and consolidated group restructuring
A foreign parent planned to place its U.S. distributing corporation under a newly formed subsidiary, then have the distributing corporation distribute all of the stock of a controlled corporation to…
PLR 1226026: IRS treats preferred shares issued by closed-end funds as equity
The IRS ruled that preferred shares to be issued by 32 closed-end management investment companies will be treated as equity for federal income tax purposes. The funds, which are regulated investment…
PLR 1226020: IRS grants more time to elect an extended NOL carryback
The IRS grants a consolidated corporate group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group showed that it acted reasonably and in good…
PLR 1226008: IRS grants more time for an extended CNOL carryback election
A consolidated group's common parent failed to timely make an election to carry back a consolidated net operating loss for an extended period under § 172(b)(1)(H). The parent relied on a qualified…
PLR 1226006: IRS grants more time for an extended CNOL carryback election
A consolidated group's common parent failed to timely make an election to carry back a consolidated net operating loss for an extended period under § 172(b)(1)(H). The parent relied on qualified tax…
PLR 1225010: IRS treats subsidiaries as joining a consolidated return despite missing consent forms
A parent company asked whether three subsidiaries should be treated as having joined its first consolidated federal income tax return for a short taxable year. The return included the subsidiaries'…
PLR 1224006: IRS approves a multi-step corporate reorganization
The IRS approved federal tax treatment for a multi-step corporate reorganization involving a conversion, a reincorporation, and contributions of interests in newly formed entities. The conversion…
PLR 1224003: IRS allows a late extended NOL carryback election
The IRS granted a consolidated group 60 days to make a late election under IRC § 172(b)(1)(H) to carry back a consolidated net operating loss for an extended period. The parent had intended to make…
PLR 1223004: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
PLR 1223003: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
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.