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 1306032: IRS waives the 60-day IRA rollover deadline after paperwork failure
The IRS considered a taxpayer who withdrew funds from an IRA intending to roll them into a new IRA. The taxpayer relied on an individual at another company to complete the rollover paperwork, but…
PLR 1306031: IRS denies a 60-day IRA rollover waiver for remodeling-related delay
The IRS considered a taxpayer who withdrew money from an IRA while remodeling a home and later decided to return the money after the 60-day rollover period had expired. The taxpayer said the…
PLR 1306030: IRS denies a 60-day IRA rollover waiver after medical delay
The IRS considered a taxpayer who received a distribution from an IRA and did not complete a rollover within 60 days. The taxpayer attributed the delay to a medical condition, disability, knee…
PLR 1306029: IRS waives a 60-day IRA rollover deadline after paperwork error
The IRS considered a surviving spouse who received a lump-sum distribution from a deceased spouse's IRA after being told that a partial withdrawal was unavailable. The taxpayer used part of the…
PLR 1305022: IRS waives the 60-day IRA rollover deadline after incorrect financial-institution advice
A taxpayer withdrew an amount from an IRA to cover an escrow account for a construction project. An employee of the credit union incorrectly said the taxpayer had more than 60 days to put the amount…
PLR 1305021: IRS approves a change in the method for picking up governmental pension contributions
Three participating governmental employers asked about changing how they pick up mandatory contributions to a defined benefit pension plan. The prior method offset the contributions against future…
PLR 1305020: IRS waives the 60-day IRA rollover deadline after an online account mix-up
A taxpayer wanted to divide an IRA among several financial institutions. While completing an online application, the taxpayer believed an account was an IRA, but it was actually a non-IRA account.…
PLR 1305019: IRS waives two 60-day IRA rollover deadlines after a bank error
Two taxpayers received distributions from separate IRAs and intended to place the funds into rollover IRAs. A bank instead placed both amounts into a non-IRA certificate-of-deposit account. The…
PLR 1305018: IRS waives the rollover deadline after a bank opens non-IRA accounts
A taxpayer moved an IRA from one bank to another using a cashier's check payable to the taxpayer's traditional IRA. The receiving bank instead opened a non-IRA savings account and a checking…
PLR 1305017: IRS waives the rollover deadline after an employer delays mailing a check
A taxpayer took an IRA distribution because of a family emergency and instructed an employer to send a larger check to the financial institution holding the IRA. The employer prepared the check…
PLR 1305016: IRS waives the rollover deadline after a disabling medical episode
A taxpayer withdrew funds from an IRA and placed them in a savings account, intending to roll them into another IRA within 60 days. The taxpayer was permanently disabled and had periodic episodes of…
PLR 1305015: IRS waives the 60-day rollover deadline after a family medical emergency
A taxpayer received a distribution from a qualified plan and intended to roll it into an IRA within 60 days. Shortly afterward, the taxpayer's mother-in-law became terminally ill, was hospitalized,…
PLR 1304013: IRS waives the 60-day rollover deadline after a medical condition
A former spouse received a distribution from a qualified plan under a divorce settlement and intended to roll it into an IRA or another qualified plan. The taxpayer said a medical condition and…
PLR 1304012: IRS waives the 60-day IRA rollover deadline after financial-institution error
A taxpayer withdrew funds from an IRA to provide short-term capital to a company owned by the taxpayer's wife. A financial advisor incorrectly told the taxpayer that the rollover deadline was June…
PLR 1303024: IRS confirms a church plan retroactive to 1974
A tax-exempt health care organization asked whether its retirement plan qualified as a church plan under IRC § 414(e). The organization was part of a religious health care structure, and the plan…
PLR 1303023: IRS waives the 60-day IRA rollover deadline
An individual received a distribution from an IRA and asked the IRS to waive the 60-day rollover requirement. The individual said a financial adviser refused to accept the deposit even though the…
PLR 1303022: IRS waives an IRA rollover deadline after the account holder's death
A surviving spouse asked the IRS to waive the 60-day rollover requirement after the account holder died before completing an intended IRA rollover. The distributed amount remained in a bank account…
PLR 1302047: IRS waives the 60-day IRA rollover deadline after a financial institution error
An IRA owner temporarily moved stock to a brokerage account to meet a lender's liquidity requirement, intending to return it to the IRA within 60 days. The financial institution did not complete the…
PLR 1302046: IRS waives the 60-day rollover deadline after an account-titling error
A pension-plan participant intended to roll a distribution into an IRA but mistakenly deposited it into a non-IRA account after being misled by the account's title and website information. The funds…
PLR 1302045: IRS approves five benefit plans as church plans
A nonprofit school controlled by a religious organization asked whether five employee benefit plans qualified as church plans under section 414(e). The IRS found that the school was tax-exempt,…
PLR 1302016: IRS approves an annuity's after-death distribution option
The IRS approved a new after-death distribution option for a non-qualified variable annuity with a guaranteed lifetime withdrawal benefit covering an owner and a non-spouse beneficiary. When the…
PLR 1302015: IRS approves an annuity's after-death distribution option
The IRS approved a new after-death distribution option for a non-qualified variable annuity with a guaranteed lifetime withdrawal benefit covering an owner and a non-spouse beneficiary. When the…
IRS waives the 60-day rollover deadline after bank misinformation
The IRS granted a taxpayer a waiver of the 60-day rollover requirement after a bank representative incorrectly treated a new account as an IRA. The taxpayer transferred funds from an existing IRA…
IRS waives the 60-day rollover deadline after an advisor's error
The IRS waived the 60-day rollover requirement for a taxpayer whose financial advisor failed to follow instructions to deposit a distribution into another IRA. The funds were instead placed in a…
PLR 1301017: IRS declines to waive the 60-day rollover deadline for two IRA distributions
An individual asked the IRS to waive the 60-day deadline for rolling two distributions from an IRA into another IRA. The individual said that a serious medical condition affected her ability to…
PLR 1301016: IRS waives the 60-day rollover deadline after a serious medical crisis
An employee received a distribution from an exempt employer trust and asked the IRS to waive the 60-day rollover deadline. The taxpayer said that serious, ongoing medical conditions, surgeries,…
PLR 1250031: IRS declines to waive the 60-day IRA rollover requirement
The IRS declined to waive the 60-day rollover requirement for taxpayers who moved an IRA distribution into two non-IRA accounts before transferring the funds back to the IRA. The taxpayers said a…
PLR 1250030: IRS waives the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for a taxpayer who intended to transfer an IRA distribution to a rollover IRA, but whose bank deposited the funds into certificates of deposit and a…
PLR 1249018: IRS approves deductions for welfare benefit fund note payments
The IRS ruled on the tax treatment of a company's prepayment of a note contributed to a welfare benefit trust and the later transfer of that note to a third party. It concluded that qualifying…
PLR 1247024: IRS grants more time for a qualified separate lines of business election
The IRS granted a diversified holding company six more months to file Form 5310-A and make a notice election for qualified separate lines of business. The company had relied on an employee-benefits…
PLR 1247023: IRS confirms church plan status and no irrevocable ERISA election
The IRS ruled that a defined benefit plan sponsored by a tax-exempt religious organization was a church plan under IRC § 414(e), retroactive to January 1, 1974. The plan covered employees of related…
PLR 1247022: IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS waived the 60-day rollover requirement for an individual who received distributions from an IRA and intended to return unused funds to an IRA. The funds were temporarily held in a…
PLR 1247021: IRS waives the 60-day IRA rollover deadline after a bank's deposit error
The IRS waived the 60-day rollover requirement for a taxpayer whose bank deposited an IRA distribution into a non-IRA certificate of deposit held by the taxpayer's revocable trust. The taxpayer had…
PLR 1247020: IRS allows a beneficiary rollover after bank failures and the participant's death
The IRS waived the 60-day rollover requirement for a taxpayer who was the brother, executor, and beneficiary of a deceased retirement-plan participant. The taxpayer had arranged for a lump-sum plan…
PLR 1246045: IRS waives the 60-day IRA rollover deadline after financial institution error
The IRS waived the 60-day rollover requirement for an individual who received distributions from an IRA and relied on erroneous advice from a financial institution. The individual deposited the…
PLR 1246044: IRS waives the 60-day rollover deadline after an inherited IRA account error
The IRS waived the 60-day rollover requirement after a custodian failed to title an inherited IRA correctly. The taxpayer had requested transfers from two IRAs into an account that was not…
PLR 1246043: IRS waives the 60-day rollover deadline after incorrect financial advice
The IRS waived the 60-day rollover requirement for an individual who relied on incorrect information from a financial institution about the time available to return funds to an IRA. The taxpayer had…
PLR 1246042: IRS waives the 60-day IRA rollover deadline after financial institution error
The IRS waived the 60-day rollover requirement for an individual who received distributions from an IRA and relied on erroneous advice from a financial institution. The individual deposited the…
PLR 1246041: IRS waives the 60-day rollover deadline after an adviser mishandles instructions
The IRS waived the 60-day rollover requirement for a participant who received a distribution from a profit-sharing plan and instructed a financial adviser to move part of it into a qualified…
PLR 1245029: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day rollover requirement for a taxpayer whose retirement-plan stock was mistakenly deposited into a non-IRA account by a financial institution. The taxpayer sold the stock…
PLR 1244024: IRS waives the 60-day IRA rollover requirement after a bank account error
The IRS waived the 60-day rollover requirement for a taxpayer whose bank deposited an IRA distribution into an unrelated trust account instead of the requested IRA rollover account. The taxpayer…
PLR 1244023: IRS waives the 60-day IRA rollover requirement after an annuity was misidentified
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew funds from an IRA annuity after financial and tax advisors failed to identify the account as an IRA. The taxpayer believed…
PLR 1244022: IRS waives the 60-day rollover requirement after an advisor moved IRA funds into a non-IRA annuity
The IRS waived the 60-day rollover requirement for a surviving spouse whose financial advisor moved an IRA distribution into a non-IRA annuity. The advisor did not tell the taxpayer that one of the…
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 1243019: IRS declines to waive the 60-day IRA rollover deadline
An older taxpayer withdrew money from an IRA to secure an assisted-living arrangement while waiting for her home to sell. The home sold after the 60-day rollover period, and the distributed amount…
PLR 1243018: IRS waives the 60-day IRA rollover deadline because of mental impairment
An IRA owner withdrew part of a distribution after a divorce settlement and missed the 60-day rollover deadline. The taxpayer submitted medical documentation that a worsening mental condition…
PLR 1243017: IRS approves Roth IRA treatment for an airline employee's estate and surviving spouse
The estate of a deceased airline employee received pension distributions that qualified for special rollover treatment under section 125 of WRERA. The IRS concluded that the estate could transfer…
PLR 1243016: IRS waives the 60-day rollover deadline after an advisor's account-number error
A taxpayer intended to transfer a distribution from her late husband's profit-sharing plan into an IRA. Her financial adviser entered the account number for a non-IRA account instead, so the…
IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan's request for a five-year automatic extension to amortize certain unfunded liabilities. The extension applied to eligible amortization charge bases established as of January…
PLR 1242025: IRS waives the 60-day rollover deadline after a bank error
The IRS waived the 60-day rollover requirement for a taxpayer who received a deceased spouse's IRA distribution and intended to roll it into her own IRA. She delivered the check to a financial…
PLR 1242024: IRS waives the 60-day rollover deadline after employer error
The IRS waived the 60-day rollover requirement for a taxpayer whose employer failed to follow written instructions to deposit a retirement-plan distribution into an IRA. The taxpayer entered the…
PLR 1242023: IRS waives the 60-day rollover deadline after a taxpayer misunderstood a 30-day account restriction
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew assets from an IRA and put them into a non-IRA money market account. The taxpayer believed, based on advice from a…
PLR 1242022: IRS waives the 60-day rollover deadline after a financial institution misdirected a distribution
The IRS waived the 60-day rollover requirement for a taxpayer whose financial institution deposited an IRA distribution into the wrong account. The taxpayer had sent instructions that amounts from…
PLR 1242021: IRS waives the 60-day rollover deadline after a taxpayer misunderstood a 30-day account restriction
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew assets from an IRA and put them into a non-IRA money market account. The taxpayer believed, based on advice from a…
PLR 1242020: IRS approves tax treatment of spun-off employer stock in a retirement plan
The IRS addressed a qualified defined contribution plan that received shares of a subsidiary when the employer spun off that subsidiary. The IRS ruled that the subsidiary shares continued to qualify…
PLR 1242019: IRS approves stock treatment after a workforce transfer and corporate spin-off
The IRS addressed two retirement plans after a corporate reorganization and the transfer of employees from one company to another. It ruled that shares transferred from the original plan to the new…
PLR 1242018: IRS grants more time to recharacterize invalid Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize Roth IRA conversions that were not permitted because their modified adjusted gross income exceeded the applicable limit. The couple…
IRS conditionally waives minimum funding requirements for a multiemployer plan
The IRS granted conditional waivers of the minimum funding standard for three plan years of a multiemployer pension plan. The plan covered employees subject to collective bargaining, had entered…
IRS treats an ESOP distribution as a lump-sum distribution eligible for NUA treatment
The IRS ruled that a participant's 2012 distribution of the entire account balance from an employee stock ownership plan would qualify as a lump-sum distribution under IRC § 402(e)(4). The…
IRS approves dividing inherited IRA assets among nine beneficiary IRAs
The IRS ruled that a trust named as the beneficiary of two IRAs qualified as a “see-through” trust, allowing the beneficiaries to be identified for required minimum distribution purposes. 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.