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 1319009: Acquisition qualified as a covered transaction for capitalization rules
The IRS ruled that a taxable acquisition of one company by a newly formed holding company was a “covered transaction” under Treas. Reg. § 1.263(a)-5(e)(3). The transaction combined two businesses,…
PLR 1319008: Partnership granted more time to elect capitalization of carrying charges
The IRS granted a partnership an additional 30 days to make a section 266 election to capitalize interest, property taxes, and other carrying charges for two taxable years. The partnership had…
PLR 1319007: Retroactive QEF election allowed after professional tax advice failed to identify a PFIC
The IRS consented to a shareholder's retroactive qualified electing fund election for an investment in a foreign corporation treated as a passive foreign investment company. The shareholder had…
PLR 1319006: Retroactive QEF election allowed for successor foreign corporation
The IRS consented to a shareholder's retroactive qualified electing fund election for an investment in a foreign corporation treated as a passive foreign investment company. The shareholder relied…
PLR 1319005: New parent granted more time to elect consolidated filing
The IRS granted a new parent corporation 60 days to make an election to file a consolidated federal income tax return for a short tax year. The election was missed because the parent reasonably…
PLR 1319004: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the taxpayer's additive process as producing refined coal, allowed…
PLR 1319003: Futures on volatility index qualified as RIC income under section 851
The IRS ruled that income and gains from a regulated investment company's futures contracts on a volatility index would qualify as “other income” derived from the fund's business of investing in…
PLR 1319002: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the additive process as producing refined coal, allowed feedstock…
PLR 1319001: Refined-coal credit positions approved for testing and facility rules
The IRS approved six requested positions concerning a refined-coal facility seeking the section 45 tax credit. The ruling accepted the additive process as producing refined coal, allowed feedstock…
TAM 1318034: Retroactive revocation of exempt status was not limited
The IRS considered whether to limit the retroactive revocation of a nonprofit organization's tax-exempt status under IRC § 501(c)(3). The organization had represented that it would provide credit…
PLR 1318033: Inherited IRA interests may be divided into four sub-IRAs
An estate inherited an individual retirement account after the account owner died without naming a beneficiary. The estate administrator planned to divide the account into four equal inherited…
PLR 1318032: 60-day rollover deadline waived after misleading advice
An IRA owner received a distribution and missed the 60-day rollover deadline after relying on an advisor's incorrect information. Part of the money was sent to an escrow agent and used to buy stock…
PLR 1318031: Rollover deadline waived after a financial institution mishandled instructions
An employee took a distribution from a former employer's 401(k) plan and instructed the plan administrator to roll most of the account into an IRA. The financial institution instead transferred only…
PLR 1318030: Three retirement plans qualify as church plans
The IRS considered whether a nonprofit hospital's defined benefit, money purchase, and tax-deferred annuity plans qualified as church plans under IRC § 414(e). The hospital was controlled by a…
PLR 1318029: Rollover deadline waived after a custodian opened the wrong account
An IRA owner intended to move retirement funds into a savings account within his IRA after a certificate of deposit matured. The custodian instead opened a non-IRA savings account, creating an…
IRS proposed revocation for failure to file required returns
The IRS proposed revoking a social welfare organization's tax-exempt status because it failed to file required Form 990 returns and did not provide the requested records or responses. The…
Other 1318027: IRS revokes a dog club's tax-exempt status
The IRS revoked a dog club's exemption under section 501(c)(3). The organization conducted dog shows, obedience training, and related matches, and it argued that these activities educated dog owners…
Other 1318026: IRS revokes a social club's tax-exempt status
The IRS revoked a social club's exemption under section 501(c)(7). The club promoted clay target shooting, conducted shooting events, and admitted special or daily members who were treated as…
Other 1318025: IRS revokes an organization's tax exemption for filing failures
The IRS proposed revoking an organization's exemption under section 501(c)(4) because it did not respond to IRS correspondence or file required Forms 990 for the relevant tax periods. The…
Other 1318024: IRS proposes revoking a neighborhood organization's exemption
The IRS proposed revoking a neighborhood organization's exemption under section 501(c)(4). The organization provided newsletters, directories, community events, and a security patrol for…
Other 1318023: IRS revokes a private residential association's exemption
The IRS revoked a residential association's exemption under section 501(c)(4). The association maintained private roads and common areas, provided security patrols, and served a restricted…
Other 1318022: IRS revokes a private homeowners association's exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association maintained private common areas, including a swimming pool, play areas, roads, and other facilities, and…
Other 1318021: IRS revokes a members-only organization's exemption
The IRS revoked a members-only organization's exemption under section 501(c)(4). The organization operated a bar and function hall, provided member benefits, and donated some income to local schools…
Other 1318020: IRS revokes a neighborhood patrol association's exemption
The IRS revoked a neighborhood patrol association's exemption under section 501(c)(4). The association hired off-duty police officers to patrol a residential subdivision, provided emergency contact…
Other 1318019: IRS revokes a dormant group's exemption for filing failures
The IRS revoked a subordinate organization's exemption under section 501(c)(4). The organization had ceased operations, had no financial resources or assets, and failed to file required returns and…
Other 1318018: IRS revokes an inactive organization's exemption
The IRS revoked an organization's exemption under section 501(c)(4) because it had stopped operating. During the examination, a representative said that the organization no longer conducted…
Other 1318017: IRS proposes revoking an agricultural and equestrian facility's exemption
The IRS proposed revoking an organization's exemption under section 501(c)(3). The organization planned to own and operate facilities for agricultural, equestrian, and other public events, but later…
Other 1318016: IRS revokes a homeowners association's section 501(c)(4) exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association restricted access to its common areas to members and guests, and used police assistance, gates, keys,…
Other 1318015: IRS proposes revoking a volunteer fire organization’s exemption
The IRS proposed revoking an organization’s exemption under section 501(c)(4). The organization was formed to provide volunteer fire and emergency services, but the IRS found almost no documented…
Other 1318014: IRS revokes a credit-counseling organization’s exemption
The IRS revoked a credit-counseling organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization initially proposed debt-management and counseling services for needy…
Other 1318013: IRS revokes a private golf and country club’s exemption
The IRS revoked a private golf and country club’s exemption under section 501(c)(4), retroactive to January 1, 20XX. The organization operated a public golf course alongside member facilities, but…
Other 1318012: IRS revokes a homeowners association’s section 501(c)(3) exemption
The IRS revoked a homeowners association’s exemption under section 501(c)(3), effective January 1, 20XX. The organization had originally been treated as a municipal corporation, but after the…
Other 1318011: IRS revokes exemption for failure to file returns and maintain records
The IRS revoked an organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization failed to respond to IRS correspondence, file required Form 990 returns, and maintain…
Other 1318010: IRS revokes section 501(c)(4) status but finds section 501(c)(7) qualification
The IRS revoked the organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization hosted social events for residents of a residential tower complex, but did not…
Other 1318009: IRS revokes an organization’s tax-exempt status
The IRS revoked the organization’s exemption from federal income tax under section 501(c)(3), effective January 1, 20XX. The letter says the organization operated for a substantial non-exempt…
PLR 1318008: IRS approves educational grants supporting international scholarship on American art
The IRS approved a private foundation’s procedures for awarding educational grants under section 4945(g)(3). The program will support scholarly publications about American art, including…
PLR 1318007: IRS grants extra time to file Form 3115 for an accounting-method change
The IRS granted a taxpayer a 60-day extension to file an original Form 3115 with an amended consolidated return. The form was needed to request an accounting-method change for repair and maintenance…
PLR 1318006: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 1318005: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 1318004: IRS declines to disallow or recapture investment tax credit after utility rate-template errors
The IRS ruled that a regulated public utility did not have to disallow or recapture investment tax credits after errors in the formula templates used to set wholesale electric and transmission…
PLR 1318003: Charitable gift of section 1250 property is not reduced by the corporate depreciation adjustment
The IRS ruled that a corporation’s charitable deduction for contributing certain section 1250 property to section 501(c)(3) organizations would not be reduced by 20 percent of the property’s…
PLR 1318002: IRS grants extra time to file Form 3115 after taxpayer relied on a tax professional
The IRS granted a taxpayer a 60-day extension to file the original Form 3115 needed to change its accounting method. The taxpayer had filed the form but failed to attach a copy to its consolidated…
PLR 1318001: Benefits from a public-employee death plan are excluded from income
A political subdivision asked about a plan that pays one-time benefits to qualifying beneficiaries of certain public employees who die or suffer a fatal injury in the line of duty. The IRS concluded…
PLR 1317026: Multiemployer plan receives five-year funding amortization extension
A multiemployer plan requested a five-year automatic extension for amortizing specified unfunded liabilities. The IRS approved the request under section 431(d)(1) after the plan submitted the…
PLR 1317025: Government employer may pick up mandatory retirement contributions
A municipality asked whether it could pick up mandatory employee contributions to a defined benefit governmental plan under section 414(h). The IRS concluded that the contributions qualify whether…
PLR 1317024: IRS waives the 60-day IRA rollover deadline
An individual received a distribution from an individual retirement annuity but missed the 60-day rollover deadline after relying on misleading information and errors by an insurance representative.…
PLR 1317023: IRS waives rollover deadline after mistaken tax withholding
A surviving spouse intended to transfer inherited IRA funds directly from one IRA to another. The financial institution mistakenly withheld an amount for federal income taxes even though the…
PLR 1317022: IRS waives rollover deadline after IRA funds were misdirected
An individual asked to change investments within an IRA, but a financial institution transferred the funds out of the IRA into a non-qualified account instead. The individual did not request a…
PLR 1317021: IRS declines to waive rollover deadline after medical-expense withdrawal
An individual withdrew money from an individual retirement annuity to pay medical expenses and insurance premiums during the individual's spouse's serious illness. The taxpayer later learned about…
IRS 1317020: Exempt status revoked after organization failed to provide records
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption effective January 1 of the redacted year. The IRS stated that the organization had not established…
PLR 1317019: IRS approves mentorship grants for disadvantaged young adults
The IRS approved a private foundation's procedures for awarding educational grants under IRC section 4945(g)(3). The program will support young adults ages 18 to 30 who have faced significant…
PLR 1317018: IRS rules that an estate settlement does not create self-dealing
The IRS ruled that an estate settlement involving a private foundation would not create direct or indirect self-dealing under IRC section 4941. The estate's surviving children agreed to purchase…
PLR 1317017: IRS distinguishes reporting rules for IRA and 529 account bonuses
The IRS ruled on the information-reporting treatment of bonuses a financial-services group planned to pay when clients opened and funded IRA or section 529 accounts. Bonuses credited to an IRA were…
IRS revokes a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC section 501(c)(7). The club operated shooting ranges, a fishing pond, a clubhouse, and related recreational facilities, and opened many of those…
IRS revokes a dog club's section 501(c)(7) exemption
The IRS revoked a dog club's exemption under IRC section 501(c)(7). The organization held dog shows, obedience trials, sanctioned matches, and other activities in which the general public regularly…
IRS revokes a campground social club's section 501(c)(7) exemption
The IRS proposed revoking a campground social club's exemption under IRC section 501(c)(7). The organization had sold its assets to pay liabilities, distributed the remaining funds to members, and…
PLR 1317013: IRS finds preferential cleanup payments jeopardize section 501(c)(4) status
The IRS ruled against a section 501(c)(4) environmental cleanup organization that proposed reducing a member's cleanup-related liability through a special fund and reimbursement agreement. The…
IRS denies section 501(c)(3) recognition after applicant fails to substantiate operations
The IRS denied an organization's application for recognition under IRC section 501(c)(3). The applicant described drug-rehabilitation, counseling, religious, and outreach activities, but did not…
IRS denies section 501(c)(3) recognition to a fee-based charity investment fund
The IRS finalized its denial of section 501(c)(3) recognition for a foreign common investment fund serving registered charities. The fund’s governing declaration did not expressly limit its purposes…
TAM finds trusts did not materially participate in an S corporation's activities
The IRS considered whether two complex trusts materially participated in the relevant activities of an S corporation for the alternative minimum tax rules. A beneficiary served as the corporation's…
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.