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 1341011: IRS approves oilfield fluid services as qualifying partnership income
The IRS ruled that income from supplying, transporting, and storing fracturing fluids, and from removing, treating, and disposing of flowback and produced water, will be qualifying income for a…
PLR 1341010: IRS grants relief for a late S corporation election
The IRS granted a corporation relief after it failed to file its S corporation election on time. The corporation intended to be treated as an S corporation beginning on a specified date and…
PLR 1341009: IRS restores S corporation status after a late QSST election
The IRS ruled that a corporation's S corporation election terminated when a trust holding its stock did not timely elect qualified subchapter S trust status. The trust had been an eligible…
PLR 1341008: IRS grants more time to elect consolidated return filing
The IRS granted a parent company and its subsidiaries more time to elect to file a consolidated federal income tax return. The group intended to make the election but did not file it by the…
PLR 1341007: IRS grants more time to elect disregarded entity status
The IRS granted a foreign eligible entity 120 more days to elect disregarded entity status for federal tax purposes. The entity had failed to timely file Form 8832 for the intended effective date.…
PLR 1341006: IRS reinstates an S corporation election after missing ESBT elections
The IRS ruled that a corporation's S corporation election was ineffective because two trusts that owned its shares had not filed the required electing small business trust (ESBT) elections. The IRS…
PLR 1341005: IRS preserves GST-tax grandfathering for modified family trusts
The IRS ruled that proposed modifications to several grandfathered family trusts would not cause the trusts to lose their exempt status for generation-skipping transfer (GST) tax purposes. The…
PLR 1341004: IRS approves a tax-free separation of two businesses
The IRS approved the proposed separation of two businesses operated within an affiliated corporate group. One corporation would contribute the assets of one business to a newly formed controlled…
PLR 1341003: IRS restores S corporation status after missed trust elections
The IRS ruled that a corporation's S corporation election terminated after a trust shareholder missed a QSST election and another trust shareholder missed an ESBT election. The IRS determined that…
PLR 1341002: IRS grants late section 754 election relief to a family partnership
The IRS granted a family limited partnership 120 additional days to make a section 754 election for Year 1 after the partnership's tax advisor failed to explain that the election was available. A…
PLR 1341001: IRS preserves liquidating trust status after a court-ordered extension
The IRS ruled that a trust created in a Chapter 11 bankruptcy liquidation remained a liquidating trust for federal tax purposes after the bankruptcy court extended its term. The remaining assets…
PLR 1340026: IRS approves picked-up pension contributions as employer contributions
The IRS ruled that mandatory pension contributions deducted from certain public employees' salaries and paid to a state retirement plan by participating employers would be treated as employer…
PLR 1340025: IRS waives the 60-day IRA rollover deadline after health problems
The IRS waived the 60-day deadline for two taxpayers to roll distributions from individual retirement accounts into rollover IRAs. One taxpayer's worsening health problems prevented a timely…
PLR 1340024: IRS waives the rollover deadline after a duplicate required distribution
The IRS waived the 60-day rollover requirement for a taxpayer who received a duplicate required minimum distribution from an IRA. A financial advisor failed to account for an earlier distribution…
PLR 1340023: IRS waives a 60-day IRA rollover deadline after a financial institution error
The IRS granted an individual a waiver of the 60-day deadline for rolling an IRA distribution into a rollover IRA. The individual had asked the financial institution whether another required minimum…
IRS revokes a fraternal organization's exemption after it failed to provide examination records
The IRS revoked an organization's exemption under section 501(c)(10). The organization was repeatedly asked to provide books, records, and other information needed to examine whether it continued to…
IRS denies section 501(c)(3) exemption to a community organization that did not substantiate its programs
The IRS issued a final adverse determination denying a community organization's application for exemption under section 501(c)(3). The organization proposed housing assistance, financial and…
IRS denies exemption to a nonprofit software licensor serving news organizations
The IRS denied a nonprofit corporation's application for section 501(c)(3) exemption. The corporation planned to develop and license publishing software to selected news organizations for fees,…
PLR 1340019: IRS approves a private foundation's Christian scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships to qualifying students. The foundation will select applicants using academic history, church relationships, work…
PLR 1340018: IRS approves an artists-and-scholars residency grant program
The IRS approved a private foundation's educational grant procedures for an artists-and-scholars residency program. Residents may receive housing, meals, studio space, art materials, travel…
PLR 1340017: IRS approves a cooperative's accelerated retirement of former members' capital credits
The IRS ruled that a rural electric cooperative could accelerate the retirement of former members’ capital-credit accounts by offsetting those credits against unpaid electric-service balances. The…
CCA 1340016: Chief Counsel advises respecting cross-border reorganizations and debt repayments
Chief Counsel analyzed whether the IRS should issue a notice of deficiency concerning a multinational group's two-stage restructuring. The advice concluded that the first reorganization and the…
PLR 1340015: IRS recognizes an interdenominational ministry as a religious order
The IRS concluded that an interdenominational Christian ministry qualified as a religious order for specified employment-tax rules. The ministry was recognized as tax-exempt under section 501(c)(3),…
PLR 1340014: IRS grants more time to allocate generation-skipping transfer tax exemption
The IRS granted a 120-day extension for a donor to allocate available generation-skipping transfer tax exemption to transfers made to two trusts. The donor's gift tax return had been prepared by an…
PLR 1340013: IRS grants more time to allocate GST exemption to three trusts
The IRS granted a 120-day extension for a decedent's estate to allocate available generation-skipping transfer tax exemption to transfers made to three irrevocable trusts. The trusts' attorney…
PLR 1340012: IRS approves a judicial reformation of a charitable remainder unitrust
The IRS concluded that a court-approved reformation of an irrevocable trust would not prevent the trust from qualifying as a charitable remainder unitrust. The trust had been intended to end at the…
PLR 1340011: IRS approves processing and logistics income as qualifying partnership income
The IRS concluded that a planned publicly traded partnership would earn qualifying income from processing two natural resources into products, and from marketing, storing, and transporting those…
PLR 1340010: IRS rules that qualifying growing activities count toward the manufacturing exception
The IRS ruled that production activities that also involve growing products can count when determining whether a controlled foreign corporation produced those products for the foreign base company…
PLR 1340009: IRS approves a two-stage REIT spin-off and related reorganizations
The IRS approved the federal tax treatment of a proposed two-stage restructuring involving a publicly traded real estate investment trust, two distributing corporations, and a newly formed…
PLR 1340008: IRS permits a retroactive qualified electing fund election for a PFIC investment
The IRS consented to a taxpayer's retroactive election to treat a passive foreign investment company as a qualified electing fund. The taxpayer had relied on an accounting firm for tax advice and…
PLR 1340007: IRS grants a late election for Canadian retirement accounts
The IRS granted a taxpayer more time to elect treaty treatment for undistributed earnings in Canadian retirement accounts. The taxpayer had moved from the United States to Canada, later returned to…
PLR 1340006: IRS grants more time for a tax-exempt controlled entity election
The IRS granted a corporation 60 days to make a late election under section 168(h)(6)(F)(ii) to avoid being treated as a tax-exempt entity for certain depreciation rules. The corporation was owned…
PLR 1340005: IRS classifies disability and death benefits from seven public plans
The IRS classified the federal income tax treatment of disability, death, and cost-of-living benefits paid under seven public retirement plans. It concluded that some duty-related disability and…
PLR 1340004: IRS approves a REIT's liquidation property sales treatment
The IRS ruled that gain from a real estate investment trust's planned sale of all its assets while winding down will not be income from a prohibited transaction. The REIT represented that it…
PLR 1340003: IRS grants more time for a consolidated NOL carryback election
The IRS granted a consolidated corporate group 60 days to make a late election for an extended carryback period for a consolidated net operating loss. The group represented that it intended to make…
PLR 1340002: IRS grants late S corporation election relief
The IRS agreed to treat a corporation as an S corporation beginning on the requested effective date even though it had no record of receiving Form 2553. The corporation's sole shareholder intended…
PLR 1340001: IRS restores S corporation status after an inadvertent shareholder transfer
The IRS determined that an S corporation's election terminated when its shares were transferred to an ineligible trust shareholder. The trust transferred the shares to an individual after the…
Determination 1339004: School's retirement and welfare plans qualified as church plans
The IRS ruled that a school's tax-sheltered annuity plan and health and welfare plan were church plans under section 414(e). The school was affiliated with a church through its founding…
Determination 1339003: IRS declined a waiver of the 60-day IRA rollover rule
The IRS declined to waive the 60-day requirement for a taxpayer who withdrew money from an IRA and later tried to deposit it into a rollover IRA. The taxpayer said that Bank A failed to advise him…
PLR 1339002: IRS declines to waive the 60-day IRA rollover requirement
An individual received distributions from three IRAs and asked the IRS to waive the 60-day rollover deadline so the money could be deposited into a new rollover IRA. The individual said the delay…
PLR 1339001: Corporate group may separate business lines through multi-step reorganizations
A publicly traded corporate group proposed a series of domestic and international reorganizations to separate two business lines. The plan included internal distributions, entity conversions,…
Determination 1338059: IRS revokes exemption after organization funded private professional-association event
The IRS issued a final adverse determination revoking an organization’s exemption under section 501(c)(3), effective November 30, 2009. The organization’s reported activity was funding an annual…
PLR 1338058: IRS waives 60-day rollover deadline after financial institution error
An individual received an IRA distribution and asked the IRS to waive the 60-day rollover deadline for part of the amount. A financial institution employee advised the individual to divide the…
PLR 1338057: IRS waives rollover deadline after annuity transfer error
An individual inherited an IRA and asked the IRS to waive the 60-day rollover deadline after a financial institution transferred the distribution into a non-IRA annuity instead of the intended…
PLR 1338056: IRS waives rollover deadline after medical impairment
An individual received an IRA distribution but missed the 60-day rollover deadline after a medical condition impaired the individual’s ability to manage financial affairs. The distribution was…
Determination 1338055: IRS revokes office-condominium association’s section 501(c)(4) exemption
The IRS revoked an office-condominium owners association’s exemption under section 501(c)(4), effective January 1 of the redacted year. The organization collected membership dues to manage and…
Determination 1338054: IRS revokes exemption after organization failed to provide records
The IRS revoked an organization’s section 501(c)(3) exemption effective October 1 of the redacted year. The organization failed to respond to repeated reasonable requests for records needed to…
Determination 1338053: IRS denies social-welfare exemption for fee-based investor network
The IRS issued a final adverse determination for an organization that connected member entrepreneurs with member investors seeking ownership interests in businesses. The organization charged annual…
Determination 1338052: IRS denies exemption to an online aid platform that solicited funds for specific individuals
The IRS finalized an adverse determination for an organization that used an online platform to connect donors with people seeking financial assistance. The organization focused on Jewish applicants,…
Determination 1338051: IRS revokes exemption for an organization that did not operate as an insurance company
The IRS revoked an organization’s exemption under IRC § 501(c)(15) after concluding that it was not providing insurance to its policyholders. The organization had issued only two policies, did not…
Determination 1338050: IRS revokes social club exemption over private services for members’ homes
The IRS revoked a social club’s exemption under IRC § 501(c)(7). The club’s employees performed maintenance, repair, trash collection, and water services for members’ personally owned homes, and the…
Determination 1338049: IRS revokes exemption for an animal-rescue organization over private expenses and inadequate records
The IRS revoked an animal-rescue organization’s exemption under IRC § 501(c)(3). The organization rescued dogs and cats, placed them in foster homes, and charged adoption fees, but it could not…
Determination 1338048: IRS revokes veterans organization’s exemption over private inurement and unsupported activities
The IRS revoked a veterans organization’s exemption under IRC § 501(c)(19). The organization did not substantiate payments to its executive director and companies connected to him, including…
Determination 1338047: IRS revokes business league’s exemption over member-specific commercial services
The IRS revoked an organization’s exemption under IRC § 501(c)(6). The organization represented Hispanic publishers but had opened membership to many other businesses, professionals, and…
Determination 1338046: IRS revokes a small insurer's exemption after its premiums failed the 50 percent test
The IRS revoked an organization's exemption under IRC § 501(c)(15) for years beginning January 1, 20xx. The organization was formed to reinsure mechanical breakdown and guaranteed automotive…
Determination 1338045: IRS revokes title-holding company’s exemption for operating commercial facilities
The IRS revoked a title-holding company’s exemption under IRC § 501(c)(2). The company held property for a related tax-exempt organization but also controlled a bingo-hall concession stand, bar,…
Determination 1338044: IRS revokes social club’s exemption over non-member services
The IRS revoked an organization’s exemption under IRC § 501(c)(7). The organization was formed around property owners and provided services including snow removal, a summer shuttle, access to…
PLR 1338043: IRS permits a private foundation’s 35% holding limit after finding non-disqualified control
A private foundation asked whether non-disqualified persons effectively controlled a corporation in which the foundation and related persons held more than 20% but less than 35% of the voting stock.…
PLR 1338042: IRS grants GST exemption relief after gift-tax return errors
Two taxpayers created trusts for their children and reported gifts to the trusts on Forms 709. Their tax professional treated the gifts as direct skips and incorrectly treated portions of the gifts…
PLR 1338041: IRS grants late election relief for foreign entity classification
A foreign eligible entity was treated by default as an association taxable as a corporation, but it intended to be classified as a disregarded entity for federal tax purposes. The entity failed 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.