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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 1204027: IRS grants extra time to recharacterize an ineligible Roth IRA conversion
The IRS granted a married couple up to 60 days to recharacterize a Roth IRA conversion that they were not eligible to make because their modified adjusted gross income exceeded the applicable limit.…
Determination 1204026: IRS grants a minimum funding waiver for a nonprofit’s retirement plan
The IRS granted a waiver of the minimum funding standard for a nonprofit organization’s retirement plan for the plan year ending June 30, 2010. The organization served neglected and abused children…
PLR 1204025: IRS waives the 60-day rollover deadline for a retirement plan distribution
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution after an employee retirement plan was terminated. The taxpayer relied on incorrect advice from a tax adviser…
PLR 1204024: IRS waives the 60-day rollover deadline for two IRA distributions
The IRS waived the 60-day rollover requirement for an older taxpayer who received distributions from two IRAs. The taxpayer said severe heart and vision problems, including surgery and recovery,…
PLR 1204023: IRS grants and modifies minimum funding waivers for a pension plan
The IRS granted a request to modify an earlier minimum funding waiver for a pension plan and granted a new waiver for a later plan year. The determination concerns a tax-exempt nonprofit hospital…
PLR 1204022: IRS grants and modifies minimum funding waivers for a pension plan
The IRS granted a request to modify an earlier minimum funding waiver for a pension plan and granted a new waiver for a later plan year. The determination concerns a tax-exempt nonprofit hospital…
CCA 1204010: Counsel discusses deductions for ESOP stock redemptions
Chief Counsel discussed whether a taxpayer could deduct the redemption of stock held by its employee stock ownership plan. The advice notes that the 2006 regulations did not apply to deductions…
PLR 1203035: IRS approves a conditional waiver of a pension plan's minimum funding standard
The IRS approved a conditional waiver of the minimum funding standard for a pension plan for the plan year ending December 31, 2011. The company had divested business operations during a downturn…
PLR 1203034: IRS waives the 60-day deadline for an IRA rollover
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from an IRA and later contributed it to an employer plan after the deadline. The taxpayer had relied on an…
PLR 1203033: IRS approves trust beneficiaries and a life-expectancy method for inherited plan distributions
The IRS ruled that the beneficiaries of a marital trust could be treated as designated beneficiaries for required minimum distribution purposes. The ruling also determined that the spouse, who had…
PLR 1202042: Trust beneficiary with shortest life expectancy controls inherited IRA distributions
A taxpayer asked whether a trust and two subtrusts qualified as see-through trusts and whose life expectancy controlled required distributions after the IRA owner and the owner's spouse died. The…
PLR 1201019: IRS waives the 60-day IRA rollover deadline after illness
The IRS waived the 60-day deadline for an IRA rollover after a taxpayer became seriously ill, was hospitalized, and was treated for cancer during the rollover period. The taxpayer deposited the…
PLR 1201018: IRS waives rollover deadline after erroneous financial advice
The IRS waived the 60-day rollover deadline for a surviving spouse who took a pension distribution after receiving erroneous advice from a financial advisor. The advisor recommended a lump-sum…
PLR 1152023: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day deadline for an individual retirement account rollover after an investment advisor sent the distributed funds to a non-IRA account instead of the new IRA account. The…
PLR 1151002: Governmental deferred compensation plan qualifies under section 457(b)
A state board asked whether its amended model deferred compensation plan for local governmental employers qualified as an eligible deferred compensation plan under section 457(b). The IRS ruled that…
PLR 1151001: Governmental deferred compensation plan qualifies under section 457(b)
A state board asked whether its amended deferred compensation plan for state and local governmental employers qualified as an eligible deferred compensation plan under section 457(b). The IRS ruled…
PLR 1150039: IRS waives the 60-day deadline for part of an IRA rollover
An individual received a distribution from an IRA and placed part of it into a non-IRA account after receiving inadequate rollover instructions from a financial company employee. The IRS determined…
PLR 1150038: IRS waives the 60-day deadline for an IRA rollover
An individual requested a waiver of the 60-day deadline for rolling an IRA distribution into another retirement account. The taxpayer misunderstood when the 60-day period began and requested relief…
PLR 1150037: IRA transfer after divorce and limits on distributions
A former spouse was awarded one-half of an IRA under a divorce agreement and judgment. The taxpayer planned to transfer that interest into an IRA in her own name and give the custodian written…
Determination 1149054: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval covered eligible amortization charge bases established as of…
Determination 1149053: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149052: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149051: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149050: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149049: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
PLR 1149048: IRS waived the 60-day IRA rollover deadline after a taxpayer's death
The IRS considered a request to waive the 60-day deadline for rolling IRA funds into another IRA. The deceased taxpayer had mental and medical conditions that affected his ability to manage his…
PLR 1149047: IRS waived the 60-day IRA rollover deadline after a bank error
The IRS considered a request to waive the 60-day deadline for rolling a distribution into an IRA. The taxpayer instructed a bank representative to complete a rollover, but the representative instead…
PLR 1149046: IRS waived the 60-day IRA rollover deadline after medical incapacity
The IRS considered a request to waive the 60-day deadline for rolling a distribution into an IRA. The taxpayer received the distribution after closing an IRA and intended to roll it into another…
PLR 1149032: IRS approved a local teachers' retirement fund dissolution and lump-sum distributions
The IRS ruled that a local teachers' retirement fund association could dissolve and distribute its remaining assets to members without losing its exemption under section 501(c)(11). The proposed…
IRS approves tax treatment for annuity termination and partnership-interest sale
The IRS approved the requested tax treatment for two trusts that planned to transfer partnership interests to a buyer in exchange for terminating life annuity contracts and receiving cash. The…
Determination 1147039: IRS approved a limited return of pension-plan contributions
The IRS approved treating certain employer contributions to a qualified defined benefit pension plan as disallowed solely for purposes of Rev. Rul. 77-200. That treatment allowed the employer to…
Determination 1147038: Prearranged retire-and-rehire would disqualify the pension plan
A multiemployer pension plan in critical status proposed a default schedule that would eliminate subsidized early-retirement benefits. The plan also proposed allowing eligible participants to retire…
PLR 1147031: IRS approves revised funded-ratio conditions for a pension plan's amortization extension
The IRS approved a pension plan's request to modify conditions attached to a prior approval of a 10-year extension for amortizing unfunded liabilities. The original approval required the plan to…
PLR 1146026: IRS waives the 60-day IRA rollover requirement
A taxpayer asked the IRS to waive the 60-day deadline for rolling a distribution from an IRA into another retirement account. The taxpayer intended to complete the rollover, but the financial…
PLR 1146025: IRS waives a 60-day rollover deadline after an institution's error
A taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA annuity distribution into a rollover IRA. The taxpayer intended to complete the rollover, but the receiving financial…
PLR 1146024: IRS declines to waive the 60-day IRA rollover requirement
A taxpayer's daughter, acting under a power of attorney, withdrew IRA funds to pay for assisted living and planned to replace the funds with proceeds from selling the taxpayer's principal residence.…
PLR 1145033: IRS grants time to recharacterize an ineligible Roth IRA conversion
The IRS granted an individual 60 days to recharacterize an amount converted from a traditional IRA to a Roth IRA as a contribution to a traditional IRA. The taxpayer had relied on incorrect…
Determination 1145032: IRS denies a minimum funding waiver request
The IRS denied a nonprofit foundation's request to waive the minimum funding standard for its plan years ending December 31, 2006, 2007, and 2008. The organization had stopped operating as a health…
Determination 1145031: IRS denies a minimum funding waiver request
The IRS denied a nonprofit foundation's request to waive the minimum funding standard for its plan years ending December 31, 2006, 2007, and 2008. The organization had stopped operating as a health…
Determination 1145030: IRS denies a minimum funding waiver request
The IRS denied a nonprofit foundation's request to waive the minimum funding standard for its plan years ending December 31, 2006, 2007, and 2008. The organization had stopped operating as a health…
PLR 1145029: IRS grants an IRA rollover waiver after incorrect advice
An individual received a distribution from an IRA and intended to roll over part of it into another IRA. During the 60-day rollover period, an employee of the financial institution incorrectly said…
PLR 1145028: IRS waives a rollover deadline after severe mental illness
An individual received a distribution from a 401(k) plan and intended to roll over part of it into an IRA. The IRS found that a severe mental health condition prevented the individual from making…
IRS waives the 60-day rollover deadline after incorrect tax information
A participant in a 401(k) plan received a full distribution of employer stock and made a partial rollover based on incorrect information about the taxable portion of the distribution. The employer…
IRS waives the 60-day rollover deadline after an account setup error
A taxpayer intended to make a direct rollover from an employer plan into an IRA, but a financial advisor mistakenly opened a non-IRA account. The plan sent the distribution to that account, and the…
IRS waives the IRA rollover deadline after a financial institution refused the deposit
A taxpayer withdrew money from an IRA to help purchase a home and planned to replace it with a bridge loan within the 60-day rollover period. On the 57th day, the taxpayer's broker refused to accept…
IRS waives the rollover deadline after incorrect required-distribution advice
A taxpayer withdrew funds from an IRA after a financial institution representative incorrectly advised him that the funds had to be distributed. He placed the money into three non-IRA savings…
PLR 1143033: IRS approves a five-year extension for amortizing unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of July 1, 2010. The extension applied to eligible amortization charge bases and…
PLR 1143032: IRS approves employer pickup of mandatory retirement contributions
A public university established a defined contribution plan for a class of employees and required participants to contribute 4 percent of compensation. The university formally agreed to pay those…
PLR 1143031: IRS waives the 60-day IRA rollover deadline because of diminished capacity
The IRS granted a waiver of the 60-day rollover requirement for an IRA distribution. The taxpayer, who was 78, represented that diminished mental capacity and moderate dementia prevented him from…
PLR 1143030: IRS waives the 60-day deadline for an IRA rollover
The taxpayer received an IRA distribution and, after receiving erroneous instructions from a financial company, placed portions of it into two accounts that were not eligible retirement accounts.…
PLR 1143029: IRS waives the 60-day deadline after a fraudulent IRA custodian caused a missed rollover
The taxpayer withdrew money from an IRA to establish a self-directed IRA with a financial institution. The institution's president falsely represented that it could act as an IRA custodian, and the…
PLR 1143028: IRS waives the rollover deadline after a Roth IRA transfer error
The taxpayer directed a wire transfer from a Roth IRA to buy a note that was intended to remain an asset of the Roth IRA. Because of an error by the IRA's transfer agent, the transfer was treated as…
PLR 1143027: IRS waives the rollover deadline after an advisor used a non-IRA account
The taxpayer moved retirement assets from one IRA to pursue an investment through another self-directed IRA. The financial advisor mistakenly deposited the assets into a non-IRA account to buy…
PLR 1142034: IRS waives the 60-day rollover deadline after a bank error
An individual received a retirement-plan distribution intending to roll it into an IRA. A bank employee mistakenly placed part of the distribution into non-IRA certificates of deposit, so the full…
PLR 1142033: IRS approves two classes of annuity vendors under a 403(b) plan
A public educational institution consolidated its separate campus 403(b) programs and selected a limited group of annuity companies for new contracts. Employees with older contracts from other…
PLR 1142032: IRS approves a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities as of August 1, 2010. The extension applies to eligible amortization charge…
PLR 1142031: IRS waives the 60-day rollover deadline after incomplete financial advice
An individual received a distribution from an IRA and did not complete a timely rollover after receiving incomplete advice and instructions from a financial institution. The institution's broker was…
PLR 1142030: IRS waives the 60-day rollover deadline after an adviser opened the wrong account
An individual received distributions from two IRAs and intended to roll the funds into another IRA within 60 days. A financial adviser mistakenly checked the wrong box on the account application, so…
PLR 1141023: IRS approves treatment of a collectively bargained welfare fund
The IRS ruled that a trust funding retiree health, life insurance, and disability benefits is a separate welfare benefit fund maintained under a collective bargaining agreement. The ruling is based…
PLR 1141022: IRS waives the 60-day IRA rollover deadline after a medical hardship
The IRS waived the 60-day deadline for a taxpayer who accidentally deposited an IRA distribution into a non-IRA account while dealing with a medical condition that impaired her ability to manage…
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.