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 1330001 grants more time to waive a consolidated net operating loss carryback
The IRS grants a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group intended to make the election but…
PLR 1329030 approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a five-year automatic extension to amortize a plan's unfunded liabilities. The approval covers liabilities described under sections 431(b)(2)(B) and 431(b)(4) of the Internal…
PLR 1329029 approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a five-year automatic extension to amortize a plan's unfunded liabilities. The approval covers liabilities described under sections 431(b)(2)(B) and 431(b)(4) of the Internal…
PLR 1329028 approves a private foundation's receipt of hedge-fund interests
The IRS rules that a private foundation's investment income from specified interests in a hedge-fund LLC will not be unrelated business taxable income under the stated facts. The IRS also concludes…
PLR 1329027 grants a five-year extension to dispose of excess business holdings
The IRS grants a private foundation an additional five years to dispose of excess business holdings received by bequest. The foundation showed that it had made diligent efforts to sell the holdings…
Determination 1329026 revokes an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization bought television listing data and provided access to members…
Determination 1329025 revokes a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC § 501(c)(7). The examination found that the club received substantial income from facility use by members of the general public and did not keep…
Determination 1329024 denies exemption to a shareholder-rights organization
The IRS denied exemption under IRC § 501(c)(6) to an organization formed to restore and maintain shareholder control over publicly traded corporations. Its members were individual and institutional…
Determination 1329023 revokes a real estate association's section 501(c)(6) exemption
The IRS revoked a real estate association's exemption under IRC § 501(c)(6). The association's primary activity was operating a multiple listing service for members, and the examination found that…
Determination 1329022: IRS revokes a homeowners association’s section 501(c)(4) exemption over private roads
The IRS revoked a homeowners association’s exemption under IRC § 501(c)(4). The organization maintained private roads and other property for owners, but its signs and access rules limited use of…
Determination 1329021: IRS denies exemption to an organization promoting an Internet identity standard
The IRS denied an organization’s application for exemption under IRC § 501(c)(3). The organization promoted a freely available Internet identity standard, developed the standard through volunteer…
Determination 1329020: IRS revokes an online university’s exemption for private inurement
The IRS revoked an online university’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The determination found that three officers benefited from repeated payments,…
Determination 1329019: IRS revokes a religious organization’s exemption over officer inurement and missing records
The IRS revoked a religious organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization spread Christian teachings through books, broadcasts, travel,…
Determination 1329018: IRS revokes arts organization’s exemption over gaming activity and missing returns
The IRS revoked an arts organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization’s primary activity was operating gaming programs, including instant…
CCA says a legal opinion is likely protected by attorney-client privilege absent waiver
Chief Counsel Advice addresses whether a legal opinion would be protected by attorney-client privilege. On the limited information provided, the advice says it would likely be privileged unless…
CCA explains filing options for a joint return with a nonresident alien spouse
Chief Counsel Advice addresses the filing status of a taxpayer whose spouse was a nonresident alien and lacked a proper taxpayer identification number when a joint return was filed. The advice says…
CCA advises that a revenue agent cannot revoke a power of attorney herself
Chief Counsel Advice addresses what a revenue agent should do when a taxpayer’s power of attorney may be ineligible to practice before the IRS. The advice says the revenue agent cannot revoke the…
PLR 1329014: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329013: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329012: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329011: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329010: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329009: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329008: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329007: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329006: IRS treats subsidiaries as having filed required consolidated-return consents
The IRS treated two subsidiaries as if they had filed the required Forms 1122 to join their parent’s consolidated federal income tax return. The group had filed a consolidated return and included…
PLR 1329005: IRS approves a tax-free spin-off to isolate potential environmental liabilities
The IRS ruled that a proposed transaction would qualify as a tax-free reorganization under IRC § 368(a)(1)(D). A corporation planned to transfer most of its business assets, except a contaminated…
PLR 1329004: IRS grants relief for an inadvertently invalid S corporation election
The IRS ruled that a corporation’s S corporation election was inadvertently invalid because a trust shareholder had not made the required ESBT election. The trust was otherwise represented to…
PLR 1329003: IRS treats a tribal corporation investment arrangement as a partnership
The IRS ruled that a corporation formed under section 17 of the Indian Reorganization Act was not a separate entity from the federally recognized tribe that organized it for federal tax purposes.…
PLR 1329002: IRS approves refined-coal testing for the section 45 credit
The IRS ruled that a taxpayer’s chemical treatment process could produce refined coal eligible for the enhanced credit described in IRC § 45. The process added chemical sorbents to coal before…
PLR 1329001: IRS grants extra time to make consolidated-return loss elections
The IRS granted a consolidated group an extension of time to file elections concerning the recognition of a loss on worthless subsidiary stock. The group represented that it had reasonably relied on…
PLR 1328036: IRS declines to waive the 60-day IRA rollover requirement
The IRS declined to waive the 60-day rollover requirement for two taxpayers who received IRA distributions and did not deposit the amounts into IRAs within the required period. The taxpayers said…
PLR 1328035: IRS says an exempt organization’s S corporation ownership will not end its exemption
The IRS ruled that a tax-exempt supporting organization could own an interest in a for-profit S corporation through a wholly owned disregarded entity without losing its tax-exempt status. The S…
PLR 1328034: IRS grants a five-year extension to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings received as a donation. The foundation represented that it had made diligent efforts to sell the…
CCA 1328033: When an examination notice may be issued to partnership partners
Chief Counsel advice addresses two separate questions about a notice of beginning of administrative proceeding, or NBAP, and a partnership examination. The advice states that the statutory…
CCA 1328032: Who may sign Form 907 for an extension of time to sue
Chief Counsel advice identifies the authority for signing Form 907 to extend the time for filing suit in an Appeals matter. It points to IRM § 8.7.7.2.4(5), which authorizes Appeals Area Directors…
CCA 1328031: Advice on losses from unpaid promissory notes and NOL carrybacks
Chief Counsel advice addresses taxpayers who reported the full face value of two promissory notes as income and later did not receive the expected payments. The advice concludes that IRC § 1341 does…
CCA 1328030: Life insurance proceeds are not included based only on a right to policy dividends
Chief Counsel advice addresses whether life insurance proceeds should be included in a decedent’s gross estate. The decedent was required by a divorce property settlement to maintain policies for a…
PLR 1328029: IRS grants relief for an improperly executed S corporation election
The IRS ruled that a corporation could be treated as an S corporation from its intended effective date even though its Form 2553 was not accepted because it was improperly executed. The ruling…
PLR 1328028: IRS grants extra time to elect an extended NOL carryback
The IRS granted a consolidated group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group represented that it had reasonably relied on a…
PLR 1328027: IRS approves bankruptcy-related tax treatment for an insurance subsidiary
The IRS ruled on the federal tax consequences of a parent company’s emergence from a Chapter 11 bankruptcy reorganization involving an insurance subsidiary. The IRS concluded that regulatory control…
PLR 1328026: IRS grants relief for a late S corporation election
The IRS ruled that a corporation could be treated as an S corporation from its intended effective date even though Form 2553 was not timely filed. The ruling granted relief under IRC § 1362(b)(5),…
PLR 1328025: IRS approves an S corporation’s redemption of non-voting stock
The IRS ruled on a proposed cash redemption of non-voting stock held by a shareholder of an S corporation. The redemption would be treated as a distribution under IRC §§ 301 and 1368 rather than as…
PLR 1328024: IRS approves a multi-subsidiary spin-off restructuring
The IRS approved specified federal tax treatment for a complex restructuring in which a foreign distributee received stock of six controlled corporations from a distributing corporation. The…
PLR 1328023: IRS treats part of a cooperative apartment loan as acquisition indebtedness
The IRS ruled that the outstanding principal amount of a loan used to buy an adjacent cooperative apartment and combine it with the taxpayer’s existing apartment was acquisition indebtedness. The…
PLR 1328022: IRS excludes damages attributable to physical injuries from gross income
The IRS ruled that an amount received under a settlement for psychological harms originating in personal physical injuries was excluded from gross income under IRC § 104(a)(2). The exclusion applied…
PLR 1328021: IRS grants extra time to elect corporate classification for an LLC
The IRS granted a single-member LLC an extension of time to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC represented that it had always intended to…
PLR 1328020: IRS says community service requirements do not make scholarships compensation
The IRS ruled that scholarship funds awarded through a charitable program would not constitute payment for services under IRC § 117(c). Participants had to complete academic and community-service…
PLR 1328019: IRS grants extra time for multiple QSub elections
The IRS granted a corporation 120 days to make elections treating several wholly owned subsidiaries as qualified subchapter S subsidiaries. The taxpayer had inadvertently filed separate S…
PLR 1328018: IRS approves mortgage interests as REIT real estate assets
The IRS ruled that specified excess-servicing rights acquired through a subsidiary could be treated as interests in mortgages on real property and therefore as real estate assets for REIT purposes.…
PLR 1328017: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election was inadvertently invalid because a trust beneficiary did not timely make a qualified subchapter S trust election. The IRS allowed the…
PLR 1328016: IRS continues S corporation treatment after a missed QSST election
The IRS ruled that an S corporation election terminated when a trust beneficiary failed to make a timely QSST election. The IRS found the termination inadvertent and allowed the corporation to be…
PLR 1328015: IRS continues S corporation treatment after a missed QSST election
The IRS ruled that an S corporation election terminated when a trust beneficiary failed to make a timely QSST election. The IRS found the termination inadvertent and allowed the corporation to be…
PLR 1328014: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328013: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328012: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328011: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328010: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328009: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
PLR 1328008: IRS grants relief after a missed QSST election
The IRS ruled that a corporation’s S corporation election terminated when a trust beneficiary failed to make a timely qualified subchapter S trust election. The IRS found the termination inadvertent…
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.