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 1220043: 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, 2008, and applies to…
PLR 1220042: IRS approves an automatic extension for a plan's unfunded liabilities
The IRS approved a plan's request for an automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2008, and applies to amortization…
PLR 1220041: IRS denies an automatic amortization extension
The IRS denied a plan's request for an automatic extension to amortize unfunded liabilities. The requested extension would have applied to the plan year beginning April 1, 2009. The IRS found that…
PLR 1220040: 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, 2008, and applies to…
PLR 1220039: IRS denies a waiver of the minimum funding standard
The IRS denied a multiemployer plan's request to waive the minimum funding standard for the plan year ending May 31, 2005. The IRS concluded that the plan did not show that at least 10 percent of…
PLR 1219039: IRS waives the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for an elderly taxpayer who intended to move IRA funds into a new IRA certificate of deposit but instead received a non-IRA certificate of deposit from…
PLR 1219038: IRS approves a conditional minimum funding waiver
The sponsor of a frozen pension plan asked the IRS to waive a minimum funding requirement after financial difficulties and poor plan investment returns. The IRS approved a conditional waiver for the…
PLR 1219037: IRS grants extra time to recharacterize a Roth IRA contribution
The taxpayer had a retirement plan containing traditional and Roth funds. When the plan was terminated, the plan administrator rolled both amounts into a traditional IRA, even though the Roth amount…
PLR 1219036: IRS waives rollover deadlines and grants recharacterization relief
The taxpayer asked the IRS to address several retirement-account errors made when financial-service personnel deposited funds into a Roth IRA instead of the intended traditional IRA. The IRS waived…
PLR 1219035: IRS grants extra time to recharacterize a Roth IRA
The taxpayer converted a traditional IRA to a Roth IRA after relying on an expected income level that was below the applicable conversion threshold. Revised partnership information later showed that…
PLR 1218040: IRS declines to waive the 60-day rollover requirement for an IRA distribution
A 63-year-old taxpayer asked the IRS to waive the 60-day deadline for rolling part of a SEP-IRA distribution into another IRA. The taxpayer said physical and mental health problems interfered with…
IRS determination 1218039: Minimum-funding waiver denied for a multiemployer plan
The IRS denied a request to waive the minimum funding standard for a multiemployer pension plan. The plan’s trustees argued that at least two contributing employers experienced substantial business…
PLR 1218038: IRS approves substitute mortality tables for a pension plan
The IRS approved a request to use substitute male and female mortality tables for specified populations in a pension plan. The approval applies for up to 10 years beginning with the plan year that…
PLR 1218036: IRS denies a law firm's request to waive its minimum funding contribution
A law firm asked the IRS to waive the minimum funding contribution for its pension plan for a specified plan year. The IRS denied the request because the firm's financial situation did not meet the…
PLR 1218035: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218034: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218033: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218032: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2008. The approval applied to the plan's amortization charge bases…
PLR 1218031: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218030: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The approval applied to the plan's amortization charge bases identified…
PLR 1218029: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2008. The approval applied to the plan's amortization charge bases…
PLR 1218028: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2011. The approval applies to the plan's eligible amortization charge bases…
PLR 1218027: IRS waives the 60-day deadline for an IRA rollover
The IRS waived the 60-day rollover requirement for a surviving spouse who received a distribution from an inherited IRA. The taxpayer intended to roll part of the distribution into an IRA, but a…
PLR 1218026: IRS waives the 60-day deadline after a bank error
The IRS waived the 60-day rollover requirement for a taxpayer whose bank placed an IRA distribution into a non-IRA account despite instructions to open a rollover IRA certificate of deposit. The…
PLR 1218025: IRS waives the 60-day deadline after an IRA transfer error
The IRS waived the 60-day rollover requirement for a 74-year-old taxpayer whose IRA distribution was transferred to a non-IRA account. The taxpayer believed an investment advisor and a financial…
PLR 1218024: IRS approves the return of certain pension-plan contributions
The IRS determined that contributions of $23,958,380 made for a defined benefit pension plan year could be treated as disallowed solely for purposes of applying Rev. Rul. 91-4. This meant that a…
PLR 1216050: IRS waives the 60-day IRA rollover deadline after serious medical problems
An individual withdrew an amount from an IRA and deposited it into another account, intending to move it into an IRA with a higher interest rate. The individual did not complete the rollover within…
PLR 1216049: IRS declines to waive the 60-day IRA rollover deadline after a calendar error
An individual withdrew money from an IRA to consolidate IRA accounts and obtain a higher rate of return. The individual said the rollover was late because the wrong date, relating to a distribution…
PLR 1216048: IRS approves a five-year extension to amortize unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a retirement plan. The extension applied to eligible amortization charge bases…
PLR 1216047: IRS waives the rollover deadline after a plan administrator omitted rollover information
The surviving spouse of a deceased plan participant received distributions from two qualified retirement plans. The plan administrator instructed the spouse to transfer the balances to a personal…
PLR 1216046: IRS approves a five-year extension to amortize unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a retirement plan. The extension applied to eligible amortization charge bases…
PLR 1215018: IRS confirms that a religious order's retirement plan is a church plan
A religious order asked whether its retirement savings plan qualified as a church plan under IRC § 414(e). The IRS concluded that the order was an integral part of a church, shared common religious…
PLR 1215017: IRS grants a conditional waiver of the minimum funding standard
The IRS considered a healthcare organization's request for a waiver of the minimum funding standard for its retirement plan for the year ending December 31, 2007. It granted the waiver under IRC §…
PLR 1215016: IRS waives the 60-day IRA rollover requirement after a bank error
A taxpayer intended to transfer funds from one IRA into another IRA but the funds were placed into a non-IRA account by mistake. The IRS found that the failure to complete the rollover within 60…
PLR 1215015: IRS waives the 60-day rollover requirement after a credit union error
A taxpayer received a distribution from an employer retirement plan and instructed a credit union to deposit it into an IRA. The credit union instead deposited the funds into a non-IRA account,…
Written determination 1210049: Minimum funding waiver request denied
The IRS denied a request for a waiver of the minimum funding standard for a plan year ending December 31, 2007. The IRS said the plan appeared close to insolvency, and it was unlikely that granting…
Written determination 1210048: Minimum funding waiver granted for an underfunded plan
The IRS granted trustees' request for a waiver of the minimum funding standard for a plan year ending September 30, 2010. The plan had been underfunded after a major employer went bankrupt and…
PLR 1210047: Inherited IRA distributions may use the older beneficiary's life expectancy
A decedent named a trust as the beneficiary of an individual retirement account, and the trust's remaining beneficiaries were two individuals. The IRS ruled that the trust qualified as a see-through…
PLR 1210046: IRS waives the 60-day rollover requirement for an IRA distribution
A taxpayer moved a distribution from an IRA into a non-IRA account intending to complete a rollover, but the 60-day period expired before the rollover was completed. The taxpayer said that the…
PLR 1210045: Inherited IRA distributions may use the surviving spouse's life expectancy
A decedent named a trust as the beneficiary of an IRA, with the surviving spouse and two children as the trust's beneficiaries. The IRS ruled that the IRA could be divided through trustee-to-trustee…
IRS grants a five-year amortization extension for a multiemployer plan
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The extension covered liabilities described under IRC § 431(b)(2)(B) and §…
IRS denies return of excess employer pension contributions
The IRS denied a request to return employer contributions made to a pension plan in excess of the maximum deductible amount. The agency found no evidence that the excess contribution resulted from a…
IRS applies minimum funding standards to a collectively bargained pension plan
The IRS addressed a pension plan's request to limit required contributions to amounts specified in collective bargaining documents. The agency concluded that the minimum funding requirements under…
PLR 1208041: IRS waives the 60-day rollover deadline after a financial institution error
The IRS waived the 60-day rollover requirement for two married taxpayers whose financial institution mistakenly deposited their IRA distributions into non-IRA accounts. The taxpayers had delivered…
PLR 1208040: IRS waives the 60-day IRA rollover deadline after a financial advisor's deposit error
An 84-year-old taxpayer received a distribution from an IRA and intended to roll the amount into another IRA. A financial advisor's office mistakenly deposited the amount into a non-IRA trust…
PLR 1208039: Beneficiaries may establish separate inherited IRAs after an estate's IRA interest passes to them
The IRS addressed an IRA owned by a decedent whose estate was the named beneficiary and whose interest passed to a trust for the decedent's four children. The children proposed to transfer their…
IRS determination 1207014: conditional minimum funding waiver granted
The IRS granted a waiver of the minimum funding standard for an employer's pension plan for the plan year ending December 31, 2007. The waiver is conditional on filing accurate Schedule MB reports,…
PLR 1207013: IRS waives the 60-day IRA rollover requirement after a duplicate distribution
The IRS waived the 60-day rollover requirement for an elderly taxpayer who received a duplicate required minimum distribution from an IRA because of an error by the financial institution. The…
PLR 1206026: IRS waived the 60-day IRA rollover requirement after a financial institution error
The IRS considered a taxpayer's request to waive the 60-day deadline for rolling a distribution from an IRA into another IRA. The taxpayer intended to complete the rollover, but a financial…
PLR 1206025: IRS waived the 60-day IRA rollover requirement after an adviser misrepresentation
The IRS considered a taxpayer's request to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer deposited the distribution into a checking account after being…
IRS approval 1206024: Return of certain nondeductible defined-benefit-plan contributions
The IRS addressed a request involving a qualified defined-benefit pension plan and employer contributions that were treated as nondeductible under Revenue Procedure 90-49. It determined that…
PLR 1206023: IRS denied a 60-day IRA rollover waiver for insufficient documentation
The IRS considered an elderly taxpayer's request to waive the 60-day rollover deadline for distributions from two IRAs. The taxpayer said a financial institution employee incorrectly told him he had…
IRS approval 1206022: Return of defined-benefit-plan contributions
The IRS approved the return of up to $104,074 in employer contributions to a qualified defined-benefit pension plan. The contributions were made for the plan year beginning January 1, 2008, and…
IRS denial 1206021: Minimum funding standard waiver denied during plan termination
The IRS denied an employer's request to waive the minimum funding standard for a defined-benefit plan for the year ending February 28, 2009. The Pension Benefit Guaranty Corporation had informed the…
IRS approval 1206020: Five-year extension for amortizing unfunded liabilities
The IRS approved a five-year automatic extension for amortizing specified unfunded liabilities of a pension plan. The extension applies to eligible outstanding amortization charge bases for the plan…
IRS determination 1205024: Five-year extension for pension plan amortization
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities. The extension applies to eligible outstanding amortization charge bases for the plan year beginning…
IRS determination 1205023: Five-year extension for pension plan amortization
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities. The extension applies to eligible outstanding amortization charge bases for the plan year beginning…
IRS determination 1205022: Pension freeze and savings plan do not trigger funding restriction
The IRS determined that a company's amendment freezing benefit accruals under its pension plan and its establishment of a section 403(b) savings plan did not trigger the restriction in IRC §…
IRS determination 1205021: 60-day IRA rollover deadline waived
The IRS waived the 60-day deadline for part of an IRA distribution after a financial advisor incorrectly completed rollover paperwork. The taxpayer intended to divide the distribution among three…
IRS determination 1205020: Conditions modified for pension amortization extension
The IRS conditionally approved a modification to a prior ruling that granted a 10-year extension for amortizing a pension plan's unfunded liabilities. The modification is effective January 1, 2009…
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.