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 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 September 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 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 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 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 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 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 May 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 request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases…
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 January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
PLR 1231020: IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS considered a taxpayer who received a distribution from an IRA intending to roll the funds into another IRA within 60 days. A financial institution mistakenly deposited the amount into a…
PLR 1231019: IRS waives the 60-day IRA rollover deadline after an annuity cancellation delay
The IRS considered a taxpayer who received an IRA distribution and invested it in an IRA annuity. Before annuity payments began, the taxpayer canceled the annuity, but the refund was delayed and the…
PLR 1231018: IRS waives the 60-day rollover deadline after an account was mistaken for an IRA
The IRS considered a taxpayer who received a distribution from a cash or deferred plan and intended to roll it into an IRA. The taxpayer and her spouse believed that an online account was an IRA,…
PLR 1230036: IRS approves a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The plan provided the required information and an actuary's certification that,…
PLR 1230035: IRS grants associated businesses a conditional pension funding waiver
Associated businesses asked the IRS to waive the minimum funding standard for a pension plan. The businesses were experiencing financial hardship after declining sales and profits, excess facility…
PLR 1230034: IRS denies a pension funding waiver because the hardship was not temporary
A mutual insurance company asked the IRS to waive the minimum funding standard for its pension plan. The company reported declining sales and revenue, but its interim financial statements showed…
PLR 1230033: IRS approves a five-year pension liability amortization extension
A pension plan asked the IRS for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The IRS approved the extension under IRC § 431(d)(1), effective for…
PLR 1230032: IRS waives the 60-day IRA rollover deadline for an elderly taxpayer
An elderly taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer represented that dementia and prior strokes impaired his memory and…
PLR 1230031: IRS confirms that a college pension plan is a church plan
A college asked the IRS whether its defined benefit pension plan qualified as a church plan under IRC § 414(e). The college was affiliated with a religious convention, shared its religious bonds and…
PLR 1230030: IRS says a successor custodian does not change legacy 403(b) account status
A financial institution asked whether replacing the custodian of certain legacy § 403(b)(7) custodial accounts would change the accounts' status under Rev. Proc. 2007-71. The existing custodian…
PLR 1230029: IRS grants more time to recharacterize an ineligible Roth IRA conversion
A married couple asked the IRS for more time to recharacterize a traditional IRA conversion as a contribution to a traditional IRA after their income made them ineligible for the Roth IRA…
PLR 1230028: IRS waives the 60-day rollover deadline after erroneous financial advice
Two taxpayers asked the IRS to waive the 60-day deadline for rolling distributions from traditional IRAs into self-directed IRAs. They relied on a financial advisor who directed the distributed…
PLR 1230027: IRS waives the 60-day Roth IRA rollover deadline after a financial institution error
An individual received a distribution from a Roth IRA and intended to roll it into a new Roth IRA. A financial institution representative instead provided paperwork for a non-IRA account and…
IRS determination 1229024: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2008. The extension covers liabilities described in IRC…
IRS determination 1229023: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2009. The extension covers eligible amortization charge bases…
IRS determination 1229022: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of January 1, 2010. The extension covers eligible amortization charge…
IRS determination 1229021: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2009. The extension covers eligible amortization charge bases…
IRS determination 1229020: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of September 1, 2009. The extension covers eligible amortization charge…
IRS determination 1229019 replaces a prior ruling and approves a five-year amortization extension
The IRS issued a replacement ruling approving a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of January 1, 2008. The extension covers…
PLR 1229018: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229017: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229016: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229015: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229014: IRS waives the 60-day rollover requirement after a family death
The IRS waived the 60-day deadline for a taxpayer who received a distribution from an IRA and completed a rollover shortly after the deadline. The taxpayer represented that a family member's death…
PLR 1229013: IRS declines to waive the 60-day rollover requirement
The IRS declined to waive the 60-day rollover requirement for a taxpayer who withdrew funds from an IRA and deposited them into a joint checking account. The taxpayer said he misunderstood an…
PLR 1229012: IRS rules on contribution limits for two multiemployer defined contribution plans
The IRS addressed contribution and deduction limits for two separate qualified defined contribution multiemployer plans maintained under a collective bargaining agreement. For the annual-additions…
PLR 1228055: IRS allows return of pension surplus from an erroneous actuarial calculation
The IRS considered whether a terminated defined-benefit plan could return surplus assets to its sponsoring taxpayer after purchasing annuity contracts for all plan liabilities. It ruled that the…
PLR 1228051: IRS approves a pension plan’s annuity settlement window
The IRS approved a pension plan amendment creating a one-time window for certain retirees and beneficiaries to exchange future annuity payments for a qualified annuity option or a lump-sum payment.…
PLR 1228047: IRS declines to waive the 60-day IRA rollover deadline
The IRS declined to waive the 60-day rollover requirement for an individual who withdrew stock from an IRA and did not complete the rollover on time. The taxpayer said an account representative…
PLR 1228046: IRS waives the 60-day IRA rollover deadline because of medical impairment
The IRS waived the 60-day IRA rollover requirement for a taxpayer who received a distribution and mistakenly deposited it into a non-IRA account. The taxpayer supported the request with medical…
PLR 1228045: IRS approves a limited lump-sum window for pension annuitants
The IRS ruled that two defined benefit plans could offer a limited window for certain participants and beneficiaries who had already begun receiving annuity payments to elect a lump-sum payment…
PLR 1228044: IRS waives the 60-day rollover deadline after an IRA owner was defrauded
The IRS waived the 60-day rollover requirement for an older taxpayer who was misled by an individual into transferring IRA funds to an account controlled by the individual and an associated company.…
PLR 1228043: IRS waives the 60-day rollover deadline for a late § 457(b) rollover
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from a governmental § 457(b) plan and transferred part of it to an IRA about a week late. The taxpayer…
PLR 1227011: IRS declines to waive the 60-day IRA rollover requirement
An individual received a distribution from an IRA and intended to roll the amount into another retirement account, but forgot to deposit the check within the 60-day period. The IRS declined to waive…
PLR 1227010: IRS waives the 60-day IRA rollover requirement after erroneous advice
An individual received a distribution from an IRA and intended to move it into a self-directed IRA, but the amount was instead placed in a non-IRA account after the individual relied on erroneous…
PLR 1227009: IRS waives the 60-day IRA rollover requirement after postal error
Two taxpayers received distributions from their IRAs and mailed checks to a financial institution to complete rollovers. The checks were returned after the 60-day rollover period had expired because…
IRS approval of a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities. The plan submitted the required information and an actuary's certification that it would…
PLR 1226037: IRS waives the 60-day rollover deadline after a financial institution error
The IRS waived the 60-day rollover requirement for a taxpayer who intended to roll a retirement-plan distribution into an IRA. The taxpayer followed instructions from a financial institution, but…
PLR 1226036: IRS waives rollover deadlines after fraudulent investment advice
The IRS waived the 60-day rollover requirement for two retirement-plan distributions after a taxpayer was misled into believing that the funds had been deposited into a rollover IRA. The taxpayer…
PLR 1226035: IRS waives rollover deadline after an IRA transfer error
The IRS waived the 60-day rollover requirement after an IRA investment was transferred into a non-IRA trust fund when custodial fees went unpaid. The taxpayer said he relied on a financial advisor…
PLR 1226034: IRS grants partial waiver of IRA rollover deadline
The IRS waived the 60-day rollover requirement for two IRA distributions that a taxpayer accidentally deposited into a non-IRA account after following misleading website prompts. The taxpayer…
PLR 1225024: IRS waives the 60-day IRA rollover requirement after memory disorder
An IRA owner missed the 60-day rollover deadline after a memory disorder caused him to overlook a second required minimum distribution. He recontributed the second distribution to the IRA after…
PLR 1225023: IRS waives the 60-day IRA rollover requirement after bank error
A taxpayer received two IRA distributions after her husband's death and intended to roll them into an IRA at a bank. An employee of the bank entered the account number for a non-IRA account, so the…
PLR 1225022: IRS waives the 60-day IRA rollover requirement after bank transfer error
An IRA owner instructed two financial institutions to transfer a distribution back into an IRA within the 60-day rollover period. One institution moved the money between individual and business…
PLR 1225021: IRS waives the 60-day IRA rollover requirement after bank advice
An IRA owner received a distribution intending to roll it into another IRA, but a bank employee advised him to use an interim non-IRA account and then purchase a life insurance policy. The policy…
PLR 1225020: IRS permits a surviving spouse to roll over an IRA distributed through a trust
A decedent named a revocable trust as the beneficiary of his IRA, and the trust required the IRA proceeds to fund a marital trust for his surviving spouse. The spouse had the right to receive all…
TAM 1225019: IRS permits aggregation of welfare benefit funds for UBTI calculations
The IRS provided technical advice about an employer's voluntary employees' beneficiary associations and a separate account used to provide retiree death benefits. It considered whether…
PLR 1224047: IRS waives the 60-day IRA rollover deadline
An IRA owner asked the IRS to waive the 60-day rollover deadline after a financial institution mistakenly transferred funds from an IRA to a non-IRA account. The taxpayer also experienced a medical…
PLR 1224046: IRS waives the 60-day rollover deadline for a plan-loan offset
A retirement plan participant asked the IRS to waive the 60-day rollover deadline after a plan loan was treated as in default and offset against the participant's account. The participant relied on…
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.