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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IRS waives the 60-day rollover deadline after a financial institution miscalculated an RMD
The IRS waived the 60-day rollover deadline for an excess IRA distribution caused by a financial institution's failure to record the taxpayer's spouse's age. That error caused the institution to…
IRS waives the 60-day rollover deadline after a delayed replacement check
The IRS waived the 60-day rollover deadline for a taxpayer who could not deposit a retirement-plan distribution in time because a credit union delayed reissuing the check to the correct payee. The…
IRS waives the 60-day rollover deadline after a taxpayer's family hardships
The IRS waived the 60-day deadline for a taxpayer who took money from an IRA and intended to put it back, but missed the deadline while dealing with his brother's death and his sister-in-law's…
IRS waives the 60-day IRA rollover deadline after a serious diagnosis
The IRS waived the 60-day rollover requirement for an individual who withdrew money from an IRA and did not complete the rollover after being diagnosed with an aggressive malignancy. The IRS…
IRS waives the 60-day IRA rollover deadline after an advisor's error
The IRS waived the 60-day rollover requirement for a taxpayer who intended to transfer funds from one IRA to another. The taxpayer's financial advisor mistakenly opened a nonqualified annuity…
IRS waives the 60-day IRA rollover deadline after incarceration
The IRS waived the 60-day rollover requirement for a taxpayer whose IRA assets were seized after his arrest and who was later incarcerated. The taxpayer’s attorney obtained release of most of the…
IRS waives the rollover deadline after a brokerage account error
The IRS waived the 60-day rollover requirement for a taxpayer who attempted to move funds from an employer profit-sharing plan into an IRA rollover account. Following instructions from a financial…
IRS declines a rollover waiver for delayed commercial-property sale proceeds
The IRS considered a married couple’s request to waive the 60-day rollover deadline for four IRA distributions used to pay off a mortgage on an investment property. The taxpayers expected to return…
PLR 1240018: Insurer owns assets supporting indexed-linked annuity options
A life insurance company asked whether it, rather than contract owners, owns assets purchased to support proposed indexed-linked investment options in non-qualified annuity contracts. The IRS ruled…
PLR 1239013: IRS grants a nonprofit hospital conditional pension funding waivers
A nonprofit critical access hospital requested waivers of the minimum funding standard for its pension plan after financial losses reduced its liquid assets and threatened its ability to meet…
PLR 1238031: IRS rules OTCBB-traded preferred stock is not publicly traded employer securities
A company asked whether a class of its preferred stock, traded on the OTC Bulletin Board, counted as publicly traded employer securities for the diversification rules of IRC § 401(a)(35). The IRS…
PLR 1238030: IRS approves a pension-plan amendment with only a de minimis liability increase
A multiemployer defined benefit plan asked whether an amendment that would let certain pensioners continue working without permanently suspending their benefits was reasonable and caused only a de…
PLR 1238029: IRS waives the 60-day IRA rollover deadline after custodian errors
An individual asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The IRS found that errors by custodians caused the funds to be placed in a non-IRA joint…
IRS determination 1237029: Five-year amortization extension for a multiemployer plan
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The extension applies to the eligible amortization charge base established as…
PLR 1237028: IRS waives the 60-day rollover deadline after adviser error and illness
An IRA beneficiary received a distribution after her spouse's death and intended to roll part of it into a qualified IRA annuity. A financial adviser accidentally marked the annuity as…
PLR 1237027: IRS waives the 60-day rollover deadline after custodian errors
An IRA custodian distributed a taxpayer's retirement assets after it stopped serving as custodian, and another financial institution converted the account and its investments without the taxpayer's…
PLR 1237026: IRS waives the 60-day rollover deadline after IRA communication errors
The taxpayer received distributions from two inherited IRAs after the death of her spouse. She intended to move the funds into IRAs in her own name, but communications with a financial institution…
PLR 1237025: IRS waives the 60-day rollover deadline after financial-adviser error
The taxpayer received a distribution from her deceased spouse's individual retirement annuity and deposited it into a non-IRA account after her long-time financial adviser incorrectly concluded that…
IRS determination 1237024: Five-year multiemployer plan amortization extension
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The extension applies to the eligible amortization charge bases established as…
PLR 1236039: IRS waives the 60-day IRA rollover deadline after a medical hardship
The IRS waived the 60-day deadline for a 78-year-old taxpayer to roll an IRA distribution into another IRA. The taxpayer said that surgery, medication, and resulting confusion impaired her ability…
PLR 1236038: IRS waives the 60-day IRA rollover deadline after a postal delay
The IRS waived the 60-day deadline for a taxpayer who mailed an IRA rollover check but whose contribution arrived four days late because of postal delays. The taxpayer had withdrawn funds from one…
PLR 1236037: IRS declines to waive the 60-day IRA rollover deadline after incorrect advice
The IRS declined to waive the 60-day rollover deadline for a taxpayer who withdrew two IRA distributions for anticipated medical expenses and later redeposited them after receiving incorrect advice…
PLR 1236036: IRS waives the 60-day IRA rollover deadline after fraudulent misrepresentations
The IRS waived the 60-day rollover deadline for a 33-year-old taxpayer whose IRA funds were transferred to a non-IRA account after fraudulent misrepresentations by an individual and a company. The…
PLR 1236035: IRS waives the 60-day rollover deadline after reliance on professional advice
The IRS waived the 60-day deadline for a taxpayer who moved a distribution from a former employer's 401(k) plan into a new plan that was later rescinded and found not to be a qualified plan. The…
PLR 1236034: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day rollover deadline after a financial institution mistakenly deposited an IRA annuity distribution into a non-IRA account. The taxpayer had instructed the institution to use…
PLR 1235030: IRS grants extra time to recharacterize Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize two Roth IRA conversions as traditional IRA contributions. The couple had converted traditional IRAs in 2009, when their income…
PLR 1235029: IRS treats an accidental duplicate IRA payment as no modification of substantially equal payments
The IRS ruled for a taxpayer who received a duplicate IRA distribution after one financial institution failed to stop payments as instructed. The taxpayer was already receiving substantially equal…
PLR 1235028: IRS letter addresses a requested waiver of the 60-day IRA rollover deadline
The taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer intended to move the money into another IRA investment, but a company employee…
PLR 1235027: IRS waives the 60-day IRA rollover deadline after a financial institution's error
The IRS waived the 60-day rollover deadline for a 60-year-old taxpayer whose financial advisor used the wrong account documents. The taxpayer intended to move money from an IRA into a new IRA, but…
PLR 1235026: IRS waives the 60-day IRA rollover deadline because of a medical condition
The IRS waived the 60-day rollover deadline for a 69-year-old taxpayer who said a neurological condition prevented her from managing her financial affairs. She had withdrawn money from an IRA…
Pension plan amendments approved as reasonable and de minimis
A company in Chapter 11 bankruptcy asked whether amendments to its pension plan were reasonable and caused only de minimis increases in plan liabilities. The amendments traded some benefit increases…
Five-year amortization extension approved for plan liabilities
A multiemployer pension plan requested a five-year automatic extension to amortize unfunded liabilities. The IRS approved the extension after finding that the plan submitted the required…
60-day rollover waiver denied
An individual asked the IRS to waive the 60-day deadline for rolling a retirement-plan distribution into another qualified retirement account. The individual said that he did not know about the…
60-day IRA rollover waiver granted
An older taxpayer moved a distribution from one IRA intending to place it into a self-directed IRA and invest through a loan opportunity. Financial professionals instead deposited the funds into a…
Medical crisis supports a 60-day IRA rollover waiver
A taxpayer withdrew funds from an IRA while preparing for a possible separation and intended to roll them into an IRA for his spouse. During the 60-day period, the taxpayer's young son experienced a…
IRS rejects requested limits on minimum pension contributions
A sponsoring employer asked the IRS to limit its pension contributions to amounts specified in collective bargaining agreements, despite potentially higher minimum funding contributions under the…
IRS approves a five-year extension for multiemployer plan liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities arising as of January 1, 2008. The extension applied to specified amortization charge bases and…
IRS approves return of certain pension contributions
The IRS approved treating specified contributions to a defined benefit pension plan as disallowed contributions solely for purposes of applying Revenue Ruling 91-4. This allowed the plan to return…
IRS approves a five-year extension for unfunded pension liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities arising as of July 1, 2009. The extension applied to eligible amortization charge bases…
IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a request from a multiemployer plan for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2011. The approval applies to eligible…
IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a request from a multiemployer plan for a five-year automatic extension to amortize unfunded liabilities existing as of July 1, 2009. The approval applies to eligible amortization…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2008. The extension applied to the plan year beginning September 1 of a…
IRS recognizes a nonprofit corporation's 401(k) arrangement as a church plan
The IRS concluded that a defined contribution plan sponsored by a church-controlled nonprofit corporation was a church plan under IRC § 414(e). The corporation was tax-exempt, controlled through an…
IRS grants a conditional minimum funding waiver to an aerospace company pension plan
The IRS granted a pension plan a conditional waiver of the minimum funding standard for a redacted plan year. The employer had experienced a sharp decline in its aircraft maintenance business, was…
IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS waived the 60-day rollover deadline for a 75-year-old taxpayer whose financial institution deposited part of an IRA distribution into a non-IRA account despite her instructions. She…
IRS waives the 60-day IRA rollover deadline because of a medical condition
The IRS waived the 60-day deadline for a taxpayer to roll a distribution from an IRA into another IRA. The taxpayer, who was age 73, said medical treatment caused short-term memory loss and impaired…
IRS approves limited reversion treatment for defined benefit plan contributions
The IRS approved a request involving employer contributions to a qualified defined benefit pension plan. It determined that contributions totaling a redacted amount may be treated as disallowed…
IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day rollover deadline for an estate after a financial institution sent a pension distribution to a nonqualified account instead of the decedent's IRA. The decedent had…
IRS waives the 60-day deadline for a partial pension rollover
The IRS waived the 60-day rollover deadline for part of a pension distribution received by a medically disabled taxpayer. The taxpayer said a medical condition, continuous anxiety, a lost check, and…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of April 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of March 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of August 1, 2009. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to amortization charge bases identified in the application…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of October 1, 2009. The extension applies to eligible amortization charge bases established on that…
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.