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 1224045: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224044: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224043: IRS waives the 60-day rollover deadline for part of a retirement-plan distribution
An older taxpayer received a retirement-plan distribution that was mistakenly deposited into a nonqualified brokerage account instead of an IRA. A representative of the financial company…
PLR 1224042: IRS recognizes three employee benefit plans as church plans
A nonprofit organization affiliated with a religious society asked whether three employee benefit plans qualified as church plans under IRC § 414(e). The organization was controlled by a committee…
PLR 1224041: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224040: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1223023: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day rollover requirement for a taxpayer who had taken a distribution from an individual retirement annuity and failed to complete the rollover because of a cognitive…
IRS approves 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 as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves 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 as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves 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 as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves 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 as of October 1, 2009. The extension applies to the eligible amortization charge bases identified…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2008. The extension applies to the amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The extension applies to the amortization charge bases identified…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of October 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS waives the 60-day rollover requirement because of a spouse's serious medical condition
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer had received the distribution while seeking a safer and more diverse investment option,…
IRS waives the 60-day rollover requirement after financial institution errors
The IRS waived the 60-day deadline for a taxpayer to roll a distribution from a SEP IRA into another eligible retirement plan. The taxpayer intended to keep an investment in a retirement plan, but…
IRS recognizes an employee retirement plan as a church plan
The IRS ruled that employees of a tax-exempt organization associated with a church are church employees for the church-plan rules. It also ruled that the organization's retirement Plan X qualifies…
IRS declines to waive a 60-day rollover deadline after a taxpayer lost household items during a move
The IRS declined to waive the 60-day deadline for rolling a distribution from an employee plan into an IRA. The taxpayer said that he was preoccupied with recovering furniture and other household…
PLR 1221057: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 1221056: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 1221055: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 1221054: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 1221052: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 1221051: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221048: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221047: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221046: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221045: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221044: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 1221039: IRS modifies funded-ratio conditions for a plan's amortization extension
The IRS approved a plan's request to modify conditions attached to an earlier approval of a 10-year extension for amortizing unfunded liabilities. The earlier approval required the plan to maintain…
PLR 1221037: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day deadline for rolling a distribution back into an IRA. A financial institution mistakenly distributed money from one IRA instead of another account, and the taxpayer did not…
PLR 1221036: IRS waives the 60-day rollover deadline after a medical emergency
The IRS waived the 60-day deadline for rolling an IRA distribution back into the taxpayer's IRA. The taxpayer had placed the distribution in another account, then underwent surgery for an extensive…
PLR 1221035: IRS waives the 60-day rollover deadline after incorrect tax advice
The IRS waived the 60-day deadline for a taxpayer to roll an IRA annuity distribution into a rollover IRA or IRA annuity. The taxpayer relied on an accountant's advice that surrendering the annuity…
PLR 1220063: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of July 1, 2009,…
PLR 1220062: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of October 1, 2009,…
PLR 1220061: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of June 1, 2009,…
PLR 1220060: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases identified in the application and…
PLR 1220059: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases identified in the application and…
PLR 1220058: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of June 1,…
PLR 1220057: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of May 1, 2008, and…
PLR 1220056: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of June 1, 2009, and…
PLR 1220055: IRS waives the 60-day rollover deadline for two retirement-plan distributions
The IRS waived the 60-day rollover requirement for two distributions from a retirement plan. The taxpayer said that caring for a seriously ill child while serving on active military duty prevented a…
PLR 1220054: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220053: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2009,…
PLR 1220052: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220051: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220050: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2009, and applies to the…
PLR 1220049: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning June 1, 2009, and applies to eligible…
PLR 1220048: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning July 1, 2009, and applies to eligible…
PLR 1220047: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning March 1, 2010, and applies to eligible…
PLR 1220046: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning September 1, 2009, and applies to…
PLR 1220045: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning August 1, 2009, and applies to eligible…
PLR 1220044: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning November 1, 2009, and applies to…
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.