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 1327002: IRS says a fund need not report payments that retain their personal-injury exclusion
The IRS ruled that a fund created during the liquidation of an insolvent life insurance company would not have information reporting obligations for certain payments to annuity beneficiaries. The…
PLR 1326009: Solar project may qualify as placed in service despite temporary curtailment
The IRS ruled that a solar power project would not be prevented from being treated as placed in service in the target year if an unfinished network upgrade caused temporary curtailment of the…
PLR 1326008: Solar project may qualify as placed in service despite temporary curtailment
The IRS ruled that a solar power project would not be prevented from being treated as placed in service in the target year if an unfinished network upgrade caused temporary curtailment of the…
PLR 1326007: New bonds qualify as refunding bonds after partnership technical termination
The IRS ruled that new bonds issued to refinance existing bonds remained refunding bonds even though ownership purchases and a technical termination of a partnership occurred within six months of…
PLR 1326005: Refined coal process qualifies for the section 45 credit rules
The IRS ruled that a taxpayer's additive process could produce refined coal eligible for the section 45 credit, subject to the statutory emissions-reduction requirements. The ruling also addressed…
PLR 1326004: Refined coal process qualifies for the section 45 credit rules
The IRS ruled that the described additive process could produce refined coal eligible for the section 45 credit, subject to the statutory emissions-reduction requirements. The ruling also addressed…
PLR 1326003: Refined coal process qualifies for the section 45 credit rules
The IRS ruled that the described additive process could produce refined coal eligible for the section 45 credit, subject to the statutory emissions-reduction requirements. The ruling also addressed…
PLR 1326002: Refined coal process qualifies for the section 45 credit rules
The IRS ruled that the taxpayer's process of mixing proprietary additives into coal could produce refined coal eligible for the section 45 credit, provided the coal met the applicable source, rank,…
PLR 1326001: IRS grants more time to spend qualified bond proceeds
The IRS granted a municipality more time to spend proceeds from qualified zone academy bonds on public school rehabilitation and equipment. The original three-year expenditure period was delayed by…
PLR 1325007: Licensing fees from active research activities are excluded from the royalty test for an ordinary loss
A parent corporation expected the stock of its wholly owned research subsidiary to become worthless. The parent asked whether licensing fees received by the subsidiary should be treated as royalties…
PLR 1325004: IRS grants extra time to elect qualified real property indebtedness treatment
An individual received discharge-of-indebtedness income through a partnership after a lender forgave debt used to acquire an interest in real property. The taxpayer did not report the income or…
IRS grants extra time for a research-cost election
A consolidated corporate group missed the deadline to elect under IRC § 59(e) to amortize certain research and experimental expenditures over ten years. The taxpayer said its tax preparer did not…
Solar project property qualifies for a possession exception
A domestic limited liability company treated as a partnership planned to develop a solar project in a United States possession. Its two members were domestic corporations, neither of which had a…
Solar project property qualifies for a possession exception
A domestic limited liability company treated as a partnership planned to develop a solar project in a United States possession. Its two members were domestic corporations, neither of which had a…
PLR 1324014: IRS grants more time to elect a multi-building low-income housing project
A taxpayer asked the IRS for more time to identify all buildings in a low-income housing project as part of a single, multiple-building project for section 42 purposes. The taxpayer said the…
PLR 1324008: IRS grants extra time for a research-cost amortization election
The IRS granted a taxpayer 60 additional days to make an election under IRC § 59(e) to amortize certain research and experimental expenditures. The taxpayer missed the election because its tax…
PLR 1324006: IRS approves an exception for solar project property in a U.S. possession
The IRS ruled that depreciable property for a solar project in a U.S. possession could qualify for an exception to the alternative depreciation system. The taxpayer was a domestic limited liability…
PLR 1324005: IRS approves an exception for solar project property in a U.S. possession
The IRS ruled that depreciable property for a solar project in a U.S. possession could qualify for an exception to the alternative depreciation system. The taxpayer was a domestic limited liability…
CCA concludes that unsupported related-party advances were not bona fide debt
Chief Counsel Advice supports the Field's position that a purported related-party loan was not bona fide debt. The record did not show a fixed maturity date, principal repayments, interest charged…
CCA 1323015: Collaboration is a partnership and cannot elect out of subchapter K
The IRS analyzed a collaboration between two corporations that developed and commercialized a product. It concluded that the collaboration was a partnership for federal tax purposes because the…
PLR 1323006: IRS ruling on redacted gross-income and deduction-timing questions
The IRS considered a taxpayer's request involving redacted facts about gross income and the proper tax year for a deduction. The released analysis discusses when a receipt is income, when an…
PLR 1323005: IRS allows specified intra-group stock-sale losses after a joint venture formation
The IRS considered a multinational consolidated group that transferred interests in several subsidiaries among related entities before forming a joint venture with an unrelated party. The group…
PLR 1322046: IRS treats a community trust and related corporation as one entity
The IRS approved treating a community trust and a related nonprofit corporation as a single entity for federal tax purposes. The organizations had a common governing body, common governing…
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 1322027: IRS grants time to file railroad track maintenance credit forms
The IRS gave a railroad company 120 days to file Forms 8900 for several tax years and claim the railroad track maintenance credit. The company had reported its integrated rail system as a…
PLR 1322023: IRS addresses income and deduction issues for a mortgage securitization business
The IRS considered a ruling request from a stockholder-owned corporation that purchases residential mortgages and mortgage-related securities, securitizes them into mortgage-backed securities, and…
PLR 1322007: IRS permits revocation of a section 83(b) election
The IRS consented to a taxpayer's revocation of an election under section 83(b) concerning shares of employer stock received for services. The taxpayer requested revocation within the 30-day period…
PLR 1322005: IRS approves refined-coal credit treatment for an emissions-reduction process
The IRS ruled on a taxpayer's proposed use of chemical additives to produce refined coal for a power plant. The ruling approved treating the resulting fuel as refined coal under section 45, subject…
PLR 1322004: IRS approves refined-coal treatment for a leased facility and blended coal
The IRS ruled on a taxpayer's use of chemical reagents at a leased facility to produce refined coal for a power plant. The process and reagents qualified for refined-coal treatment under section 45,…
PLR 1322003: IRS approves refined-coal treatment for a leased facility and blended coal
The IRS ruled on a taxpayer's use of chemical reagents at a leased facility to produce refined coal for a power plant. The process and reagents qualified for refined-coal treatment under section 45,…
TAM 1321019: Court order fixed the date of discharge of indebtedness
The IRS considered when an S corporation's debt was discharged after a settlement with its creditor. The settlement required payments and a court order dismissing the related claims, and it included…
PLR 1321017: IRS rules that three officers are not covered employees under section 162(m)
The IRS ruled that three officers of a publicly held corporation were not covered employees for the corporation's taxable year. Two officers served as the corporation's principal financial officer…
PLR 1321012: IRS approves charitable transfers of trust remainder and unitrust interests
The IRS ruled that a married couple may transfer their charitable remainder unitrust remainder and unitrust interests to a charitable organization. The couple will irrevocably give up the power to…
CCA 1320014: IRS advises that a structured investment does not qualify for the dividends-received deduction
Chief Counsel advised that a domestic corporate group was not entitled to a dividends-received deduction for distributions routed through a controlled foreign corporation and a regulated investment…
PLR 1320003: IRS approves refined-coal credit treatment and testing methods
The IRS considered a partnership's planned production and sale of refined coal treated with chemical additives to reduce emissions. It ruled that the product could qualify as refined coal under IRC…
CCA 1319010: Park restrictions can affect the value of donated mineral property
Chief Counsel Advice addresses the valuation of land and mineral rights donated to the National Park Service for purposes of a charitable contribution deduction under IRC § 170. The advice states…
PLR 1319009: Acquisition qualified as a covered transaction for capitalization rules
The IRS ruled that a taxable acquisition of one company by a newly formed holding company was a “covered transaction” under Treas. Reg. § 1.263(a)-5(e)(3). The transaction combined two businesses,…
PLR 1319004: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the taxpayer's additive process as producing refined coal, allowed…
PLR 1319002: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the additive process as producing refined coal, allowed feedstock…
PLR 1319001: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the additive process as producing refined coal, allowed feedstock…
PLR 1318006: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 1318005: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 1318004: IRS declines to disallow or recapture investment tax credit after utility rate-template errors
The IRS ruled that a regulated public utility did not have to disallow or recapture investment tax credits after errors in the formula templates used to set wholesale electric and transmission…
PLR 1318001: Benefits from a public-employee death plan are excluded from income
A political subdivision asked about a plan that pays one-time benefits to qualifying beneficiaries of certain public employees who die or suffer a fatal injury in the line of duty. The IRS concluded…
PLR 1317007: Disability benefits qualify for exclusion as compensation for injuries or sickness
The IRS ruled that certain disability benefits paid to police officers and firefighters, or continuation benefits paid to survivors, would not be included in gross income. The ruling applied to…
PLR 1317003: Termination payment must be capitalized and may be recovered under section 167
The IRS considered the tax treatment of a payment made to terminate two franchise agreements. It ruled that the payment had to be capitalized as a newly created intangible under the regulations for…
IRS grants extra time to make a qualified real property debt election
The IRS granted an individual an additional 45 days to make an election to exclude cancellation-of-debt income from qualified real property business indebtedness and reduce the basis of depreciable…
IRS grants extra time to make a qualified real property debt election
The IRS granted an individual an additional 45 days to make an election to exclude cancellation-of-debt income from qualified real property business indebtedness and reduce the basis of depreciable…
IRS grants extra time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled corporation 60 days to make an election under section 168(h)(6)(F)(ii). The election allows the corporation to be treated as not tax-exempt for purposes of…
IRS grants extra time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled corporation 60 days to make an election under section 168(h)(6)(F)(ii). The election allows the corporation to be treated as not tax-exempt for purposes of…
Taxpayer granted extra time to elect treatment of capital gains as investment income
An individual asked for more time to elect to treat net capital gains as investment income for purposes of the investment interest deduction. The election had been missed because the taxpayer's…
PLR 1315002: Consolidated group receives more 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 carryback period for a consolidated net operating loss. The group missed the election deadline…
PLR 1315001: Disability retirement benefits partly excluded as workers' compensation
The IRS considered disability retirement and survivor benefits paid under a statewide public employee retirement system. It concluded that accidental disability benefits for work-related injuries or…
TAM 1314043: Government-contract receipts qualify partly as domestic production gross receipts
The IRS analyzed two government contracts involving the design, development, production, and delivery of defense-related systems and related software. It concluded that receipts from qualifying…
PLR 1314024: IRS approves § 115 exclusion for a state agency's investment company
A state agency formed a wholly owned limited liability company to invest public funds and pursue various trading and investment strategies. The agency asked whether the company's income would be…
PLR 1314023: IRS approves § 115 exclusion for a state agency's real estate lending company
A state agency formed a wholly owned limited liability company to invest in commercial real estate loans. The agency asked whether the company's income would be excluded from gross income under IRC…
PLR 1314022: IRS approves § 115 exclusion for a state agency's real estate subsidiary
A state agency formed a parent company and a wholly owned subsidiary to acquire, hold, and sell a real estate investment. The taxpayers asked whether the subsidiary's income would be excluded from…
PLR 1314021: IRS approves § 115 exclusion for a state agency's real estate acquisition company
A state agency formed a wholly owned company to acquire, hold, and sell real estate investments using a third-party loan facility. The taxpayers asked whether the company's income would be excluded…
PLR 1314005: IRS allows an ordinary worthless-stock deduction after a foreign subsidiary changes classification
A domestic parent planned to change an insolvent foreign subsidiary's federal tax classification from a corporation to a disregarded entity. The subsidiary owned an interest in a foreign…
CCA 1313020: Publisher's book-development activities did not qualify for the domestic production deduction
The IRS considered whether a publisher's work on books qualified as manufacturing, production, growth, or extraction of qualifying production property for the former domestic production activities…
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.