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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1332013: IRS finalizes adverse determination for proposed Islamic educational broadcaster
The IRS finalized an adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization proposed television programming, seminars, publications, and…
PLR 1332012: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
PLR 1332011: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
PLR 1331012: IRS declines to waive the 60-day IRA rollover deadline
The IRS declined to waive the 60-day rollover requirement for a taxpayer who completely liquidated an IRA and transferred the proceeds to a non-IRA account. The taxpayer said she misunderstood a tax…
PLR 1331011: IRS waives the 60-day rollover deadline after duplicate IRA payments
The IRS waived the 60-day rollover requirement for a taxpayer who received an unintended duplicate IRA payment during a transfer between financial institutions. The taxpayer relied on a financial…
PLR 1331010: IRS declines waiver for tax withheld from 401(k) and IRA distributions
The IRS declined to waive the 60-day rollover requirement for amounts withheld from a taxpayer's 401(k) and IRA distributions. The taxpayer rolled over the net proceeds but wanted to roll over the…
PLR 1331009: IRS waives the 60-day rollover deadline after a financial institution error
The IRS waived the 60-day rollover requirement for a taxpayer whose financial institution sent an IRA distribution to a non-IRA account despite written rollover instructions. The taxpayer did not…
IRS revokes a foundation's tax exemption for serving private and commercial interests
The IRS revoked a foundation's recognition as a § 501(c)(3) organization effective January 1, 2006. The final adverse determination says the foundation operated in substantial part to promote a…
IRS revokes a family association's exemption for serving private interests
The IRS revoked a family association's recognition as a § 501(c)(3) organization. The association planned to manage and protect family land, sell timber, hold family reunions, and provide…
IRS denies social-welfare exemption to a fee-based project facilitator
The IRS denied a proposed § 501(c)(4) organization's application for exemption. The organization planned to identify sustainable development projects and connect them with a charitable funding…
IRS revokes an insurance company's § 501(c)(15) exemption after controlled-group receipts exceed the limit
The IRS revoked an insurance company's exemption under § 501(c)(15) after determining that the company's gross receipts had to include receipts from related companies under the controlled-group…
PLR 1331004: IRS approves a revised nuclear decommissioning funding schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's contributions to a nuclear decommissioning fund. The request was required because the taxpayer's nuclear plant operating…
PLR 1331003: IRS approves a revised nuclear decommissioning funding schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's contributions to a nuclear decommissioning fund. The request was required because the taxpayer's nuclear plant operating…
PLR 1331002: IRS confirms certain liquid urea sales qualify as partnership income
The IRS ruled that income from a publicly traded partnership's non-retail sales of liquid urea to petroleum products distributors can be qualifying income under § 7704(d)(1)(E). The partnership…
PLR 1331001: IRS grants relief for a foreign entity classification election
The IRS consented to a foreign entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity had previously changed its…
PLR 1330047: IRS denies rollover waiver because the contribution was timely
An individual received a retirement-plan distribution and asked the IRS to waive the 60-day rollover requirement because of the medical condition and death of the individual's mother. The IRS found…
PLR 1330046: IRS waives the 60-day rollover requirement after a spouse's death
The IRS waived the 60-day rollover requirement for an individual who received a distribution from a deceased spouse's IRA. The taxpayer represented that grief, a medical condition, and related…
IRS approves private foundation scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships and fellowships to graduate students conducting research or study through an international exchange program. The…
IRS approves scholarship procedures for employees and retirement-community families
The IRS approved a private foundation's scholarship procedures for employees of a management-services company, their dependents, and children or grandchildren of residents of a retirement community.…
IRS finalizes adverse determination denying a group ruling for subordinates
The IRS finalized an adverse determination denying a parent organization’s request for a group ruling covering its subordinate organizations. The package explains that the subordinates’ activities…
IRS revokes exempt status after an organization fails to substantiate operations
The IRS revoked an organization’s recognition as exempt under § 501(c)(3), effective on the redacted date. The organization did not produce documents needed to establish that it operated exclusively…
IRS revokes an organization’s exempt status after it fails to file Form 990
The IRS revoked an organization’s recognition as exempt under § 501(c)(3), effective July 1 of the redacted year. The organization did not file its required Form 990 for a tax period ending June 30,…
IRS reclassifies a museum from section 509(a)(2) to section 509(a)(1)
The IRS changed a museum’s foundation classification from an organization described under § 509(a)(2) to one described under §§ 509(a)(1) and 170(b)(1)(A)(vi), effective January 1 of the redacted…
IRS denies exemption to a commercial consignment store that offered limited job training
The IRS denied an organization’s application for exemption under § 501(c)(3). The organization planned to operate a public consignment store and provide limited job training to people with special…
IRS denies exemption to a motorcycle-parts business controlled by related individuals
The IRS denied an organization’s application for exemption under § 501(c)(3). The organization planned to sell motorcycle parts and accessories through a website and use profits to support…
CCA explains when IRS personnel must report third-party contacts
Chief Counsel Advice addresses when IRS personnel must report communications with third parties on Form 12175. The advice explains the statutory exceptions for authorized contacts, jeopardy to…
CCA advises on revoking a taxpayer representative’s power of attorney
Chief Counsel Advice addresses how an IRS revenue agent should handle a taxpayer’s power of attorney when the representative may be unresponsive or ineligible to practice before the IRS. The advice…
CCA advises that infrastructure assets appear to be dedicated improvements
Chief Counsel Advice recommends that an examination team abandon its position that certain infrastructure assets are intangible assets with an indeterminate useful life. The advice says more facts…
CCA analyzes self-cancelling notes used in transfers of closely held stock
Chief Counsel Advice analyzes a decedent’s transfers of stock to grantor trusts in exchange for promissory notes with self-cancelling features. The advice concludes that the difference between the…
CCA explains when overpayment interest begins for refund claims
Chief Counsel Advice addresses when overpayment interest begins on refund claims for two tax years. The advice concludes that interest is allowed from the date the taxpayer became overpaid, which…
CCA concludes a foreign tax refund claim was untimely
Chief Counsel Advice considers whether a taxpayer timely claimed a refund after changing a foreign tax credit to a deduction and carrying an increased net operating loss to another year. The advice…
CCA addresses deduction and funding treatment of scheduled pension payments
Chief Counsel Advice considers whether payments connected with an acquisition and certain defined benefit pension plans could be deducted or capitalized, and whether they could count toward minimum…
PLR 1330029 grants late election relief for foreign entity classification
The IRS grants a foreign eligible entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had inadvertently failed to timely file Form 8832.…
PLR 1330028 grants late disregarded-entity election relief
The IRS grants a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file Form 8832. The IRS concludes that…
PLR 1330027 treats ceramic proppant income as qualifying partnership income
The IRS rules that income from mining, processing, and marketing kaolin and bauxite for use as ceramic proppants is qualifying income under the publicly traded partnership rules. The partnership…
PLR 1330026 treats proppant and ceramic product income as qualifying income
The IRS rules that income from mining, processing, and marketing specified sand and ceramic products for use as proppants, together with related well stimulation products, is qualifying income under…
PLR 1330025 grants treaty exemption for a Canadian fund's U.S. income
The IRS rules that U.S.-source dividends and interest derived by a Canadian investment fund will be exempt from U.S. income tax under Article XXI(3) of the U.S.-Canada income tax treaty. The fund is…
PLR 1330024 treats oilfield fluid and water services as qualifying income
The IRS rules that a publicly traded partnership's income from supplying, transporting, and storing fluids for oil and natural gas wells is qualifying income under IRC § 7704(d)(1)(E). The ruling…
PLR 1330023 treats oilfield fluid handling services as qualifying income
The IRS rules that a planned publicly traded partnership's income from supplying, transporting, storing, and heating fluids for oil and natural gas wells qualifies under IRC § 7704(d)(1)(E). The…
PLR 1330022 approves tax treatment for multiple corporate separations
The IRS grants requested rulings concerning two internal spin-offs, a foreign parent's reincorporation, and a later demerger separating two businesses. It treats the first and second internal…
PLR 1330021 grants a retroactive qualified electing fund election
The IRS consents to an individual's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer became a U.S. resident, did not know the…
PLR 1330020 grants a retroactive qualified electing fund election
The IRS consents to an individual's retroactive qualified electing fund election for shares of a passive foreign investment company. The taxpayer became a U.S. resident, did not know the foreign…
PLR 1330019 grants a retroactive qualified electing fund election
The IRS consents to an individual's retroactive qualified electing fund election for shares of a passive foreign investment company. The taxpayer became a U.S. resident, later sold the shares, and…
PLR 1330018 approves a merger and redemption transaction for an S corporation
The IRS rules on a proposed transaction involving an S corporation, its continuing shareholders, and a minority shareholder. The continuing shareholders will form a new corporation, contribute their…
PLR 1330017 approves a merger and redemption transaction for an S corporation
The IRS rules on a proposed transaction involving an S corporation, its continuing shareholders, and a minority shareholder. The continuing shareholders will form a new corporation, contribute their…
PLR 1330016 approves a direct annuity contract exchange after the owner's death
The IRS rules that a beneficiary may directly transfer the value of five annuity contracts inherited from the beneficiary's mother to a new annuity contract without recognition under IRC §…
PLR 1330015 grants more time to opt out of automatic GST exemption allocation
The IRS grants the executor of an estate 120 additional days to elect out of the generation-skipping transfer tax exemption's automatic allocation rules. The underlying transfers were cash and a…
PLR 1330014 grants more time to elect partnership classification
The IRS grants an entity 120 additional days to file an election to be treated as a partnership for federal tax purposes. The entity had intended to change its classification from an association…
PLR 1330013 grants more time to elect corporate classification
The IRS grants a foreign entity 120 additional days to file Form 8832 electing to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make that…
PLR 1330012 provides relief for an inadvertent S corporation termination
The IRS provides relief for an inadvertent termination of an S corporation election caused by trust shareholders that were not treated as qualified subchapter S trusts. One trust did not make the…
PLR 1330011 approves transfers of inherited IRA rights to charities
The IRS rules that an estate's assignment of inherited IRA rights to two charitable beneficiaries will not be treated as a transfer under IRC § 691(a)(2). The estate and trust were authorized to…
PLR 1330010 restores S corporation treatment after passive-income termination
The IRS provides relief after an S corporation's election terminated because it had accumulated earnings and profits and more than 25 percent passive investment income for three consecutive years.…
PLR 1330009 grants more time to elect disregarded-entity status
The IRS grants a foreign subsidiary 120 additional days to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The subsidiary had always intended to make that…
PLR 1330008 approves a mortgage-loan sale by a governmental bond agency
The IRS rules that a state governmental housing agency's proposed sale of mortgage loans purchased with tax-exempt bond proceeds will not cause the agency or any portion of it to be treated as a…
PLR 1330007 approves a tax-free separation of two corporate businesses
The IRS rules that a planned contribution and distribution will qualify as a tax-free reorganization under IRC § 368(a)(1)(D) and a tax-free separation under § 355. The transaction separates one…
PLR 1330006 excludes certain controlled foreign corporation income from foreign base company income
The IRS rules that a controlled foreign corporation's distributive share of income from a partnership's production and sale of a commodity under a long-term output contract is not foreign base…
PLR 1330005 approves testing and qualification methods for refined coal
The IRS rules that coal treated with a specified chemical process can qualify as refined coal under IRC § 45(c)(7), provided it is produced from feedstock coal meeting the stated source or rank…
PLR 1330004 approves tax treatment for a related-company stock sale and liquidation
The IRS rules on a proposed sale of stock within a consolidated corporate group followed by the liquidation of the sold subsidiary. The stock sale will be treated under IRC § 304 as a deemed stock…
PLR 1330003 extends the spending period for qualified school construction bond proceeds
The IRS grants a political subdivision an extension to spend available project proceeds from qualified school construction bonds. Construction delays caused by contractor defaults and the resulting…
PLR 1330002 approves a multinational separation of Business 2
The IRS rules on a large corporate restructuring intended to separate Business 2 from Business 1 and the taxpayer's other businesses. The proposed steps include foreign and domestic asset transfers,…
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.