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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IRS revokes a social club's exemption after it ceases operations
The IRS revoked a social club’s exemption under section 501(c)(7), effective July 1 of the redacted year. The organization had ceased active operations, did not provide requested books and records,…
IRS revokes a civic organization's exemption after it operated a public bar
The IRS revoked an organization's tax exemption under section 501(c)(4). The organization operated a bar for its members and the general public, and the IRS concluded that this activity was not…
IRS revokes a dissolved organization's tax exemption
The IRS revoked an organization's exemption under section 501(c)(4), effective on a redacted date. The organization told the IRS that its exemption did not meet its purposes, stopped doing business,…
IRS revokes an organization's exemption after missed reporting
The IRS revoked an organization's tax-exempt status after it failed to file required Forms 990 for two tax periods and did not timely respond to IRS requests for the information. The examination…
PLR 1323029: Foundation's art subsidiary is functionally related and its management fees are not UBTI
The IRS considered a private foundation's plan to receive all stock of a corporation holding an artist's collection and copyrights. The foundation planned to use those assets for exhibitions,…
IRS denies exemption for fee-based credit-repair activities
The IRS denied an organization's application for recognition under section 501(c)(3). The organization proposed credit counseling, credit education, budget education, and a fee-based do-it-yourself…
IRS revokes a section 501(c)(4) organization's exemption for missing records
The IRS revoked a section 501(c)(4) organization's exemption after the organization failed to provide records needed to examine its Forms 990 and failed to meet reporting requirements under sections…
IRS revokes a section 501(c)(4) organization's exemption for nonresponse
The IRS revoked a section 501(c)(4) organization's exemption after it failed to respond to repeated requests for records and failed to file required Forms 990 for a tax period ending June 30 of a…
IRS denies exemption to organization advocating for polygamy-related legal change
The IRS denied an organization's application for section 501(c)(3) exemption. The organization described its work as educational, charitable, and supportive of a polygamous community, including…
IRS denies exemption to donor-fund organization tied to a for-profit platform
The IRS denied an organization's application for section 501(c)(3) exemption. The organization proposed receiving donations, allowing donors to identify charitable causes, and distributing funds to…
CCA explains when section 409A grandfathering rules may apply to a deferred compensation plan
Chief Counsel Advice addresses whether the section 409A transition rules apply to a deferred compensation plan for the open years under review. The advice says the transition rules do not apply and…
CCA addresses trust fund recovery penalties after worker reclassification
Chief Counsel Advice concludes that a trust fund recovery penalty may apply even when an employer never withheld taxes from workers it treated as independent contractors. The advice explains that a…
CCA concludes that unsupported related-party advances were not bona fide debt
Chief Counsel Advice supports the Field's position that a purported related-party loan was not bona fide debt. The record did not show a fixed maturity date, principal repayments, interest charged…
CCA concludes that invalid Forms 872 cannot revive an expired assessment period
Chief Counsel Advice concludes that the Forms 872 at issue were invalid. Forms 872 are agreements extending the period for assessment of tax. The advice says that, on the submitted facts, the IRS…
CCA addresses federal tax liens on property transferred by beneficiary deed
Chief Counsel Advice addresses whether a federal tax lien under IRC § 6321 remains attached to property that passes at death by a beneficiary deed created under state law. The advice distinguishes…
CCA recommends judicial approval under IRC § 6334
Chief Counsel Advice addresses the procedure the Service should follow in the matter described in the memorandum. The advice records a consensus that the Service should seek judicial approval as…
Supplemental PLR leaves a prior corporate reorganization ruling in force after transaction changes
The IRS supplemental private letter ruling addressed changes to a previously ruled corporate separation and distribution plan. The taxpayer withdrew requested rulings about several restructuring…
PLR 1323016: REIT financing interests in structural improvements qualify as real-estate assets
The IRS considered a planned REIT that would finance permanent structural improvements to buildings and other facilities. It ruled that the REIT's interests in those improvements, secured by the…
CCA 1323015: Collaboration is a partnership and cannot elect out of subchapter K
The IRS analyzed a collaboration between two corporations that developed and commercialized a product. It concluded that the collaboration was a partnership for federal tax purposes because the…
PLR 1323014: IRS grants relief for an inadvertent S corporation termination
The IRS considered a corporation whose S corporation election was inadvertently terminated because of a specified event. The corporation represented that the termination was not motivated by tax…
PLR 1323013: IRS grants late-election and inadvertent-ineffectiveness relief for S corporation status
The IRS considered a corporation whose intended S corporation election had the wrong effective date and ownership information, was signed by an unauthorized person for a trust shareholder, and…
PLR 1323012: IRS grants late-election and inadvertent-ineffectiveness relief for S corporation status
The IRS considered a corporation whose intended S corporation election had the wrong effective date and ownership information, was signed by an unauthorized person for a trust shareholder, and…
PLR 1323011: IRS grants more time for an extended consolidated NOL carryback election
The IRS considered a consolidated corporate group that missed the deadline to elect an extended carryback period for a consolidated net operating loss. The group showed that it reasonably relied on…
PLR 1323010: IRS grants more time to elect consolidated-return treatment
The IRS considered a parent corporation and subsidiaries that missed the deadline to elect consolidated-return treatment after an acquisition. The taxpayers showed that they reasonably relied on…
PLR 1323009: IRS grants more time for an insurance company to make the §831(b) election
The IRS considered a property and casualty insurance company that wanted to elect the alternative tax under section 831(b). The company said it missed the election deadline after relying on a…
PLR 1323008: IRS grants a consolidated group more time to file section 1.1502-36 elections
The IRS considered a consolidated group that had not timely filed specified elections relating to reductions of subsidiary stock bases and tax attributes after a series of distributions and a later…
PLR 1323007: IRS approves gift and estate tax treatment of a charitable lead annuity trust
The IRS considered a taxpayer's creation of a charitable lead annuity trust that would pay a fixed annual amount to a private foundation for a specified term, with the remaining property then…
PLR 1323006: IRS ruling on redacted gross-income and deduction-timing questions
The IRS considered a taxpayer's request involving redacted facts about gross income and the proper tax year for a deduction. The released analysis discusses when a receipt is income, when an…
PLR 1323005: IRS allows specified intra-group stock-sale losses after a joint venture formation
The IRS considered a multinational consolidated group that transferred interests in several subsidiaries among related entities before forming a joint venture with an unrelated party. The group…
PLR 1323004: IRS approves variable-contract fund investment without investor-control treatment
The IRS considered a regulated investment company offered through insurance-company separate accounts that planned to invest in a central fund. The central fund would also be available indirectly to…
PLR 1323003: IRS approves variable-contract fund investment without investor-control treatment
The IRS considered a regulated investment company offered through insurance-company separate accounts that planned to invest in a central fund. The central fund would also be available indirectly to…
PLR 1323002: IRS approves variable-contract fund investment without investor-control treatment
The IRS considered a regulated investment company offered through insurance-company separate accounts that planned to invest in a central fund. The central fund would also be available indirectly to…
PLR 1323001: IRS approves variable-contract fund investment without investor-control treatment
The IRS considered a regulated investment company offered through insurance-company separate accounts that planned to invest in a central fund. The central fund would also be available indirectly to…
PLR 1335028: IRS waives the 60-day retirement-plan rollover deadline after medical injury
An individual received a distribution from an eligible retirement plan and intended to roll it into an IRA within 60 days. A medical injury during the rollover period required hospitalization and…
Other 1322054: IRS revokes a charity's exemption over commercial operations and private benefit
The IRS revoked a charitable organization's exemption under section 501(c)(3), effective on the date stated in the final determination. The release says the organization operated primarily through…
Other 1322053: IRS denies exemption to a commercial truck-and-tractor-pull organization
The IRS denied section 501(c)(3) exemption to an organization formed around an annual truck-and-tractor-pull event. The release says the event was the organization's primary activity, with revenue…
PLR 1322052: IRS waives the 60-day IRA rollover deadline after a medical misunderstanding
The IRS waived the 60-day deadline for an individual to roll a distribution from an IRA into a rollover IRA. The individual had medical limitations and did not realize that a certificate of deposit…
PLR 1322051: IRS recognizes a private school's pension plan as a church plan
The IRS ruled that a private nonprofit college preparatory school's defined-benefit pension plan qualified as a church plan under section 414(e). The school was associated with a religious order…
PLR 1322050: IRS grants a conditional pension minimum-funding waiver after supplier disruption
The IRS granted a company a conditional waiver of an unpaid required minimum pension contribution for a specified plan year. The company manufactured made-to-order products and experienced temporary…
PLR 1322049: IRS declines to waive the 60-day IRA rollover deadline after funds paid a mortgage
The IRS declined to waive the 60-day deadline for rolling an IRA distribution into an IRA. The taxpayer said that a spouse's final illness and death, together with severe financial hardship, caused…
PLR 1322048: IRS approves an employer-related scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to qualifying dependent children of employees and related employees. The program uses an independent selection committee…
PLR 1322047: IRS approves a need-based scholarship program for local students
The IRS approved a private foundation's procedures for scholarships to graduating high school seniors who meet academic, financial-need, residency, and enrollment criteria. The program may award up…
PLR 1322046: IRS treats a community trust and related corporation as one entity
The IRS approved treating a community trust and a related nonprofit corporation as a single entity for federal tax purposes. The organizations had a common governing body, common governing…
IRS revokes an organization's section 501(c)(3) exemption for operating as a social club
The IRS revoked an organization's recognition as a section 501(c)(3) public charity. The organization primarily operated recreational facilities, a function hall, a bar, and related services for…
IRS revokes a social club's section 501(c)(7) exemption for excess nonmember income
The IRS revoked a social club's exemption under section 501(c)(7). The club operated a clubhouse, golf course, and recreation facilities for members and the general public, while membership declined…
IRS revokes a golf club's section 501(c)(7) exemption for excess nonmember income
The IRS revoked a golf club's exemption under section 501(c)(7). The club advertised discounted golf to the general public, and the examination found that nonmember income exceeded the limits for an…
IRS retroactively revokes an organization's section 501(c)(3) exemption for unsupported foreign activities
The IRS revoked an organization's section 501(c)(3) exemption, effective from the redacted date on which it was founded. The organization said it trained volunteers and helped children abroad, but…
IRS denies exemption to an organization proposing foreign surveillance and housing programs
The IRS denied section 501(c)(3) exemption to an organization proposing foreign surveillance, communications, and housing projects. The organization could not show that it controlled funds sent to…
PLR 1322040: IRS says a vessel owner need not register or file Form 720-CS when a manager operates the vessel
The IRS ruled that a company owning a petroleum vessel was not required to register as a vessel operator under section 4101. The company had no employees and had hired a separate manager to operate…
PLR 1322039: IRS grants an estate 120 more days to make the 2010 basis election
The IRS granted the personal representative of an estate 120 additional days to file Form 8939 and make the section 1022 election. The decedent died in 2010, and the representative had retained tax…
PLR 1322038: IRS grants a foreign entity 120 more days to elect disregarded-entity status
The IRS granted a foreign business entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election…
PLR 1322037: IRS grants a foreign entity 120 more days to elect disregarded-entity status
The IRS granted a foreign business entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election…
PLR 1322036: IRS says corrective distributions did not terminate an S corporation election
The IRS ruled that an S corporation's election did not terminate when some shareholder distributions were temporarily disproportionate. The corporation's governing documents gave all shares…
PLR 1322035: IRS preserves tax treatment for restructured annuity and life-insurance contracts
The IRS ruled on the tax treatment of annuity and life-insurance contracts being restructured as part of an insolvent insurer's liquidation. The restructuring would reduce benefits and replace the…
PLR 1322034: IRS grants a consolidated group more time to waive an NOL carryback
The IRS granted a consolidated corporate group 45 additional days to file an irrevocable election to relinquish the entire carryback period for a consolidated net operating loss. The parent had…
PLR 1322033: IRS recognizes a foreign electronic exchange as a qualified board or exchange
The IRS determined that a foreign electronic futures and options exchange was a qualified board or exchange under section 1256(g)(7)(C). The exchange represented that its contracts were marked to…
PLR 1322032: IRS says bankruptcy reorganization will not limit specified pre-change losses
The IRS ruled on a bankrupt company's planned ownership change under a Chapter 11 reorganization. The reorganized company would issue all of its stock to a qualified settlement fund holding assets…
PLR 1322031: IRS grants more time for a trust severance and reverse QTIP election
The IRS granted an estate 120 additional days to divide a marital trust into GST-exempt and GST-non-exempt trusts and make a reverse QTIP election for the exempt trust. The estate had filed an…
PLR 1322030: IRS approves a revised nuclear decommissioning fund schedule
The IRS approved a taxpayer's revised schedule of annual amounts for funding the decommissioning of a nuclear power plant. The taxpayer had a qualifying direct ownership interest in the plant and…
PLR 1322029: IRS approves a revised nuclear decommissioning fund schedule
The IRS approved a taxpayer's revised schedule of annual amounts for funding the decommissioning of a nuclear power plant. The taxpayer had a qualifying direct ownership interest in the plant and…
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.