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 1350017: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for an investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350016: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for an investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350015: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for its investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350014: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for its investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350013: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for its investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350012: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for its investment in a foreign corporation treated as a passive foreign investment company. The…
PLR 1350011: IRS permits a retroactive QEF election for a PFIC investment
The IRS considered a corporation's request to make a retroactive qualified electing fund election for its investment in a foreign corporation treated as a passive foreign investment company. The…
CCA 1350010: IRS declines to rule on a captive insurer's reinsurance pool arrangement
Chief Counsel considered a foreign insurance company that elected to be taxed as a domestic corporation and participated in a reinsurance pool. The company requested rulings that it qualified as an…
CCA 1350009: IRS declines to rule on a captive insurer's reinsurance pool arrangement
Chief Counsel considered a foreign insurance company that elected to be taxed as a domestic corporation and participated in a reinsurance pool. The company requested rulings that it qualified as an…
CCA 1350008: IRS declines to rule on a captive insurer's reinsurance pool arrangement
Chief Counsel considered a foreign insurance company that elected to be taxed as a domestic corporation and participated in a reinsurance pool. The company requested rulings that it qualified as an…
PLR 1350007: IRS approves a complex corporate separation followed by a reverse acquisition
The IRS approved the proposed tax treatment of a large corporate group's plan to separate one business into Controlled and distribute its stock to the parent company's shareholders, either through a…
PLR 1350006: IRS approves section 382 treatment for a parent spin-off and related contribution
The IRS ruled on the section 382 consequences of a corporate group's spin-off of its parent company and a related contribution of assets by a subsidiary. The ruling treated the spin-off date as a…
PLR 1350005: IRS restores S corporation status after an inadvertent termination
The IRS considered an S corporation whose passive investment income exceeded 25 percent of gross receipts for three consecutive years while it had accumulated earnings and profits. Those conditions…
PLR 1350004: IRS restores S corporation status after a trust holds stock beyond its eligibility period
The IRS considered an S corporation whose shareholder's grantor trust continued to hold the corporation's stock after the two-year period allowed following the shareholder's death. That caused the S…
PLR 1350003: IRS grants extra time to elect disregarded-entity classification
The IRS granted a foreign, wholly owned entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the…
PLR 1350002: IRS grants extra time to elect disregarded-entity classification
The IRS granted a foreign, wholly owned entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the…
PLR 1350001: Planned subsidiary liquidation and related property transfers receive tax treatment under Sections 332, 301, and 351
A parent company planned to dissolve a subsidiary after a change in state law eliminated the reason for maintaining the subsidiary's special structure. The subsidiary would liquidate into another…
PLR 1349029: Transfers between disability and defined contribution plans are not taxable events
A state government maintained a defined benefit plan and a defined contribution plan for its employees. Under proposed disability procedures, a participant who became totally and permanently…
PLR 1349028: Company gets 60 days to make a late qualified-separate-line election
A parent company and its subsidiary maintained separate lines of business and wanted the subsidiary treated as a qualified separate line of business for employee-plan testing. Their benefits…
PLR 1349027: Eight plans qualify as church plans
A religious health-care community and its nonprofit affiliates maintained eight retirement, welfare, and insurance plans. They asked whether the plans qualified as church plans under Section 414(e),…
PLR 1349026: Medical emergency qualifies for a 60-day IRA rollover waiver
An individual received a distribution from an IRA and deposited it into several bank accounts. A medical emergency and hospitalization lasted beyond the 60-day rollover period, preventing the…
PLR 1349025: Failed wire transfer qualifies for a 60-day IRA rollover waiver
A taxpayer received an IRA distribution and timely attempted to wire part of it back into the IRA. The transfer failed because one digit was missing from the account number, but the financial…
IRS proposes revocation of an organization's Section 501(c)(3) status
The IRS proposed revoking an organization's tax-exempt status under Section 501(c)(3). The examination found that the organization used a related for-profit entity to handle its day-to-day…
IRS revokes 501(c)(3) status for a fee-based debt management operation
The IRS issued a final adverse determination revoking an organization's exemption under Section 501(c)(3), effective June 1, 20XX. The organization mainly enrolled clients in debt management plans,…
IRS denies 501(c)(3) exemption for an open-source software website
The IRS denied a nonprofit organization's application for recognition under Section 501(c)(3). The organization maintained a website that distributed open-source computational fluid dynamics…
IRS revokes a forensic-examiner association's Section 501(c)(6) status
The IRS revoked an association's exemption under Section 501(c)(6), effective January 1, 20XX. The association represented forensic examiners, but a related for-profit company controlled its…
IRS changes an organization's foundation classification to Section 509(a)(2)
The IRS modified an organization's private-foundation classification, effective January 1, 20XX. The organization had previously been treated as publicly supported under Sections 509(a)(1) and…
IRS denies Section 501(c)(6) status to a proposed internet-standards league
The IRS denied an organization's application for exemption under Section 501(c)(6). The organization planned to develop and license a new internet standard for storing and controlling redacted…
IRS revokes a homeowners association's Section 501(c)(4) status
The IRS revoked a homeowners association's exemption under Section 501(c)(4), effective March 1, 20XX. The association restricted access to its common areas to members and their guests, using gates,…
IRS revokes exemption after organization ceases operations
The IRS revoked an organization's Section 501(c)(3) exemption effective December 31, 20XX. The organization had stopped operating, so it was no longer operated exclusively for an exempt purpose. The…
IRS revokes 501(c)(3) status for missing records and improper asset distribution
The IRS revoked an organization's Section 501(c)(3) exemption effective June 1, 20XX. The organization failed to produce records needed to show that it operated exclusively for exempt purposes,…
CCA 1349015: Foreign branch and disregarded entity transactions affect foreign tax credits
This Chief Counsel Advice addresses how transactions involving foreign branches and disregarded entities should be treated for U.S. tax and foreign tax credit purposes. Transactions between a…
CCA 1349014: First assessment extension controls the refund look-back period
This Chief Counsel Advice addresses the refund look-back period when a taxpayer and the IRS sign multiple agreements extending the assessment period. It concludes that the first extension agreement,…
CCA 1349013: Payments to incorporated veterinarians generally require information reporting
This Chief Counsel Advice considers whether payments made in the course of a trade or business to a corporation providing veterinary services must be reported under IRC § 6041. It concludes that…
PLR 1349012: IRS permits a retroactive qualified electing fund election
The IRS consented to a domestic partnership’s retroactive qualified electing fund election for an investment in a passive foreign investment company. The partnership had relied on a qualified tax…
PLR 1349011: IRS permits a retroactive QEF election after reliance on tax advisors
The IRS consented to a domestic partnership’s retroactive qualified electing fund election for an investment in a passive foreign investment company. The partnership had relied on two tax advisors…
PLR 1349010: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a domestic partnership’s retroactive qualified electing fund election for an investment in a passive foreign investment company. The partnership had acquired shares over several…
PLR 1349009: IRS grants more time for a consolidated group’s extended NOL carryback election
The IRS granted a consolidated group 90 days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline and represented…
PLR 1349008: IRS grants more time for a consolidated group’s NOL carryback election
The IRS granted a consolidated group 60 days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline and represented…
PLR 1349007: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation established reasonable cause for the late election and may be treated as an S corporation from…
PLR 1349006: Proposed spin-off qualifies as a tax-free reorganization
A parent corporation proposed to separate one business into a newly formed subsidiary and distribute the subsidiary's stock to the parent's shareholders. The plan also included exchanging some…
PLR 1349005: IRS grants more time to divide a reverse-QTIP trust
An estate had made a QTIP election, a reverse QTIP election, and an allocation of generation-skipping transfer tax exemption to a marital trust. After the filing, a regulation allowed certain trusts…
PLR 1349004: Natural gas processing and related services generate qualifying income
A publicly traded limited partnership planned to convert butane into butadiene and to handle related byproducts. It would provide processing, marketing, storage, and transportation services under…
PLR 1349003: IRS grants extra time to elect IC-DISC status
A domestic corporation intended to elect IC-DISC status for its first taxable year but did not timely file Form 4876-A. The taxpayer attributed the missed filing to a misunderstanding between its…
PLR 1349002: Trust division does not trigger additional transfer or income tax consequences
Trustees proposed dividing an old irrevocable trust into three separate trusts, one for each of a beneficiary's family lines, so the shares could be managed under different investment approaches.…
PLR 1349001: Grantor trust treatment controls a proposed asset transfer
The IRS considered two trusts, one revocable and one irrevocable, and a proposed transfer of a partnership interest from the first trust to an LLC for cash and a promissory note. The IRS ruled that…
PLR 1348018: IRS waives the 60-day IRA rollover requirement
An elderly taxpayer received an IRA distribution and intended to roll it into another IRA, but the receiving bank opened a non-IRA account instead. The IRS concluded that the failure to complete the…
PLR 1348017: IRS waives rollover deadlines after financial hardship and misinformation
A taxpayer received distributions from two IRAs after his wife's death and intended to roll both amounts into another IRA. He delayed because of financial and emotional stress, unfamiliarity with…
PLR 1348016: IRS approves a private foundation's scholarship selection procedures
A private foundation asked the IRS to approve its procedures for awarding scholarships to students pursuing undergraduate or graduate study in the arts and sciences. The IRS approved the procedures…
CCA 1348015: Counsel discusses the limitations period for section 6702 penalties
Chief Counsel attorneys discussed whether a statute of limitations applies to assessments of penalties under IRC § 6702 for frivolous submissions. The message says the IRS argued in briefs that no…
CCA 1348014: Counsel discusses lien priority after revocation of a release
Chief Counsel addressed the effect of revoking a release of a federal tax lien. The message states that the release extinguished the underlying IRC § 6321 lien, and that revocation would revive the…
CCA 1348013: Counsel agrees with the technical position on GRAT asset distributions
Chief Counsel confirmed its position on applying IRC § 469(j)(6) to distributions of assets from a grantor retained annuity trust (GRAT). Counsel agreed with the position taken by the Technical…
CCA 1348012: Counsel outlines profits-interest and partnership-interest issues
Chief Counsel provided initial reactions to a case involving profits interests and partnership interests transferred for services. The message explains the safe harbor in Rev. Proc. 93-27, as…
PLR 1348011: IRS permits limited nonrecognition in a foreign-parent liquidation
A foreign parent corporation proposed to liquidate its U.S. subsidiary after transferring the assets and liabilities of two operating subsidiaries to a new limited partnership. The IRS ruled that…
TAM 1348010: IRS treats finished buss cables as taxable bow accessories
The IRS considered whether a finished buss cable for a compound bow is a taxable part or accessory under IRC § 4161(b)(1)(B)(i). The cable is made from polyethylene fiber, sold in standard lengths…
PLR 1348009: IRS restores S corporation treatment after an inadvertent shareholder transfer
An S corporation unintentionally transferred its shares to an ineligible shareholder when purchase funds were sent to the wrong party. The parties later transferred the shares to the intended…
PLR 1348008: IRS grants a trust more time to make a section 663(b) election
A trust mistakenly filed its federal income tax return using a fiscal year instead of the calendar year. It intended to make a section 663(b) election for distributions credited to beneficiaries…
PLR 1348007: IRS permits gain from an eminent-domain payment to be reported outside the installment method
A corporation received an initial payment when a state seized its property under eminent domain law and deferred gain recognition under IRC § 1033 while it pursued a claim for additional…
PLR 1348006: IRS approves a tax-deferred transfer of structured settlement assets to a new corporation
A group of insurance companies planned to move structured settlement annuities and related payment obligations from a subsidiary being liquidated into a new corporation. The IRS ruled that the…
PLR 1348005: IRS approves a tax-free spin-off of a controlled subsidiary
A publicly traded corporation planned to separate one business from its other operations by distributing all of the stock of its controlled subsidiary to its shareholders. The IRS ruled that 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.