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.

42,150 determinations and counting · Newest release October 16, 2026
42,150 determinations

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DET

IRS revokes a veterans organization's section 501(c)(19) exemption

The IRS revoked a veterans organization's exemption under section 501(c)(19), effective on the stated date. The organization had eight active members and 51 members at large, and its primary…

201252027·December 28, 2012
Revocation
DET

IRS denies a financial literacy organization's section 501(c)(3) exemption

The IRS denied tax-exempt status to an organization that planned to provide financial literacy tools, services to low- and moderate-income households, and consulting services to small businesses.…

201252026·December 28, 2012
Denied
DET

IRS denies a literary publisher's section 501(c)(3) exemption

The IRS denied tax-exempt status to an organization that planned to publish and promote literary works, including films, books, poetry, and music. The determination found that the activities were…

201252025·December 28, 2012
Denied
DET

IRS denies a mixed-use community development organization's section 501(c)(3) exemption

The IRS denied tax-exempt status to an organization proposing mixed-use housing, community development, art museums, and educational and cultural programs. The organization did not have a valid…

201252024·December 28, 2012
Denied
DET

IRS revokes an inactive organization's section 501(c)(3) exemption

The IRS revoked an organization's section 501(c)(3) exemption because it failed to provide information requested during an examination. The organization reported that it had been inactive and had…

201252023·December 28, 2012
Revocation
DET

IRS revokes a childcare organization's section 501(c)(3) exemption

The IRS revoked a childcare organization's section 501(c)(3) exemption because its actual operations differed materially from the information used to grant exemption. The organization accepted…

201252022·December 28, 2012
Revocation
DET

IRS revokes a psychologist's section 501(c)(3) exemption

The IRS revoked a psychologist's section 501(c)(3) exemption after finding that the organization operated in a commercial manner and did not provide evidence of charitable activity. The examination…

201252021·December 28, 2012
Revocation
DET

IRS revokes an organization's exemption and changes its foundation classification

The IRS revoked the organization’s section 501(c)(3) exemption because it did not provide the books and records needed to establish continued qualification. The examination also found that the…

201252020·December 28, 2012
Revocation
PLR

IRS approves a modified scholarship grant program

The IRS approved a private foundation’s modified scholarship grant-making program under section 4945(g)(1). The changes added extracurricular-activity achievement grants to existing leadership,…

201252019·December 28, 2012
Approved
PLR

PLR 201252018: IRS approves notice procedures for a vehicle leasing company's like-kind exchange program

The IRS ruled that a vehicle leasing company’s written notice procedures satisfied the requirements for assigning sale and purchase agreement rights to a qualified intermediary in a deferred…

201252018·December 28, 2012
Approved
PLR

PLR 201252017: IRS approves a split-off of two controlled corporations from an S corporation

The IRS ruled that a proposed transaction in which an S corporation would contribute assets to two newly formed controlled corporations and distribute their stock to different shareholder groups…

201252017·December 28, 2012
Approved
CCA

CCA 201252015: Chief Counsel advises on payments made before an assessment period expires

Chief Counsel advised that the Service assessed additional tax too late for two tax years, but should not refund the tax and interest the taxpayers paid before the assessment periods expired.…

201252015·December 28, 2012
Advice
PLR

PLR 201252014: IRS approves tax treatment for a multi-step corporate restructuring

The IRS ruled on the tax treatment of a complex restructuring by an affiliated group that wanted to separate two businesses. The proposed steps included entity conversions, a subsidiary merger,…

201252014·December 28, 2012
Approved
PLR

PLR 201252013: IRS grants late-election relief for S corporation status

The IRS ruled that a corporation had reasonable cause for failing to timely file its election to be treated as an S corporation. The corporation intended its S election to take effect when it was…

201252013·December 28, 2012
Approved
PLR

PLR 201252012: IRS approves cash-or-stock distributions by a prospective REIT

The IRS ruled that a publicly traded corporation planning to elect REIT status could make special distributions in which shareholders chose cash or common stock. The cash available for each…

201252012·December 28, 2012
Approved
PLR

PLR 201252011: IRS approves tax treatment for a cross-border acquisition and reorganization

The IRS ruled on the tax consequences of a transaction involving a publicly traded foreign target, a cross-border amalgamation, and a series of acquisitions and redemptions. The ruling treated the…

201252011·December 28, 2012
Approved
PLR

PLR 201252010: IRS allows section 1033 deferral for utility relocation reimbursements

The IRS ruled that a public utility could elect to defer gain under section 1033 on payments it received for removing and relocating utility equipment at the direction of a condemning authority. The…

201252010·December 28, 2012
Approved
PLR

PLR 201252009: IRS granted late-election relief for REIT and taxable REIT subsidiary elections

The IRS granted a real estate investment trust an extension of time to elect REIT status for a taxable year. It also allowed the REIT and its subsidiary to make a late election treating the…

201252009·December 28, 2012
Approved
PLR

PLR 201252008: IRS ruled on stock sales, distributions, and a planned corporate liquidation

The IRS ruled on a series of completed and proposed transactions among a parent company and foreign and domestic subsidiaries. The ruling addressed the tax treatment of cross-chain stock sales, a…

201252008·December 28, 2012
Approved
PLR

PLR 201252007: IRS treated an inadvertently invalid S corporation election as effective

The IRS ruled that a corporation's S corporation election was inadvertently invalid because an ineligible shareholder held an interest on the effective date. The corporation represented that the…

201252007·December 28, 2012
Approved
PLR

PLR 201252006: IRS granted late-election relief to reattribute a subsidiary's tax attributes

The IRS granted a consolidated group an extension of time to make an election reattributing a subsidiary's net operating loss carryover to the parent. The election followed a stock sale that…

201252006·December 28, 2012
Approved
PLR

PLR 201252005: IRS ruled that a public rehabilitation program did not create reportable income for property owners

The IRS ruled that a political subdivision did not have to file information returns for property owners whose privately owned infrastructure was rehabilitated through a government program. The…

201252005·December 28, 2012
Approved
PLR

PLR 201252004: IRS granted late GST trust election relief

The IRS granted a taxpayer 120 days to make a generation-skipping transfer tax election treating an irrevocable trust as a GST trust. The taxpayer had reported prior gifts but failed to make the…

201252004·December 28, 2012
Approved
PLR

PLR 201252003: IRS granted late GST trust election relief

The IRS granted a taxpayer 120 days to make a generation-skipping transfer tax election treating an irrevocable trust as a GST trust. The taxpayer had reported prior gifts but failed to make the…

201252003·December 28, 2012
Approved
PLR

PLR 201252002: IRS approved specified cross-border corporate reorganizations

The IRS approved specified federal income tax treatment for a multinational group's completed and proposed reorganizations. The ruling covered transfers of stock and assets among related…

201252002·December 28, 2012
Approved
PLR

PLR 201252001: IRS restored S corporation treatment after an inadvertent termination

The IRS ruled that a corporation's S corporation election terminated after it issued interests to ineligible shareholders and created a second class of interests. The corporation represented that…

201252001·December 28, 2012
Approved
DET

IRS revoked an organization's § 501(c)(3) exemption for failure to substantiate operations

The IRS issued a final adverse determination revoking an organization's tax exemption under IRC § 501(c)(3), effective January 1, 2005. The organization did not provide enough information about its…

201251022·December 21, 2012
Revocation
PLR

PLR 201251020: IRS approved performing-arts grant procedures for a private foundation

The IRS approved a private foundation's procedures for two performing-arts grant programs. One program would support established artists, and the other would support nominated artists with the…

201251020·December 21, 2012
Approved
DET

IRS denied exemption and church classification for an internet-based religious organization

The IRS issued a final adverse determination concluding that a religious organization did not qualify for exemption under IRC § 501(c)(3). The organization operated primarily through the internet,…

201251018·December 21, 2012
Denied
CCA

CCA 201251017: Tenancy by the entirety does not defeat the small-partnership exception

Chief Counsel Advice addressed whether holding a partnership interest as a tenancy by the entirety affects the small-partnership exception. The advice concluded that a tenancy by the entirety is not…

201251017·December 21, 2012
Advice
CCA

CCA 201251016: Two benefit programs were treated as window benefits

Chief Counsel Advice characterized the benefits described in a Form 886-A as window benefits. The advice noted that only two programs were provided over an approximately ten-year period. Because…

201251016·December 21, 2012
Advice
CCA

CCA 201251015: Resident qualified for a treaty stipend exclusion for up to five years

Chief Counsel Advice concluded that, on the particular facts presented, a resident fell within paragraph (1)(a)(ii) of Article 19 of the applicable treaty. The resident therefore appeared eligible…

201251015·December 21, 2012
Advice
CCA

CCA 201251014: CCA addresses who is automatically the tax matters partner

Chief Counsel advice addressed who becomes a partnership's tax matters partner when no valid designation has been made. The advice states that the general partner becomes the tax matters partner…

201251014·December 21, 2012
Advice
CCA

CCA 201251013: CCA addresses designation of an indirect partner as tax matters partner

Chief Counsel advice addressed whether an indirect partner may be designated as a partnership's tax matters partner. The advice states that the Service may designate an indirect partner as tax…

201251013·December 21, 2012
Advice
CCA

CCA 201251012: CCA addresses wagering tax liability for a bookmaker using an offshore data service

Chief Counsel advice considered whether the wagering excise tax applies when a United States bookmaker uses a foreign company to receive and maintain bettors' wagering information. The foreign…

201251012·December 21, 2012
Advice
PLR

PLR 201251011: IRS grants extra time to elect corporate classification

The IRS granted an eligible business entity an additional 120 days to file Form 8832 and elect to be classified as an association taxable as a corporation. The entity's default federal tax…

201251011·December 21, 2012
Approved
PLR

PLR 201251010: IRS grants relief for a late S corporation election

The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation intended to be treated as an S corporation from the redacted effective date, but it did not…

201251010·December 21, 2012
Approved
PLR

PLR 201251009: IRS permits revocation of an investment-income election after a software error

The IRS granted taxpayers 60 days to revoke an election that treated qualified dividends and capital gains as investment income. The taxpayers had made the election on Form 4952, but computerized…

201251009·December 21, 2012
Approved
PLR

PLR 201251008: IRS grants extra time to file a consolidated return election

The IRS granted a corporate parent and members of its affiliated group 45 days to make a consolidated return election for a short taxable year. The group missed the regulatory deadline after the…

201251008·December 21, 2012
Approved
PLR

PLR 201251007: IRS grants late S corporation election relief to an LLC

The IRS granted an eligible limited liability company relief for a late S corporation election. The company had elected to be treated as an association taxable as a corporation, intended to elect S…

201251007·December 21, 2012
Approved
PLR

PLR 201251006: IRS approves a proposed tax-free corporate separation

The IRS ruled on a proposed transaction in which a corporation would transfer one business to a newly formed controlled corporation and distribute that corporation's stock through an internal and…

201251006·December 21, 2012
Approved
PLR

PLR 201251005: IRS approves certain foreign income for a REIT's gross-income tests

The IRS ruled that certain inclusions from controlled foreign corporations and passive foreign investment companies would qualify under a real estate investment trust's 95-percent gross-income test.…

201251005·December 21, 2012
Approved
PLR

PLR 201251004: IRS grants extra time for a section 754 election

The IRS granted a limited liability limited partnership 120 days to make a late section 754 election. The partnership had failed to make the election for the year in which a member died. The IRS…

201251004·December 21, 2012
Approved
PLR

PLR 201251003: IRS addresses a subsidiary's departure from a consolidated group

The IRS ruled on a proposed transaction involving a privately held parent and several domestic and foreign subsidiaries. The parent would acquire additional stock of a subsidiary and transfer that…

201251003·December 21, 2012
Approved
PLR

PLR 201251002: IRS addresses capital contributions in a section 382 ownership change

The IRS ruled that certain capital contributions made before a corporation's ownership change would not be treated as contributions made under a plan whose principal purpose was to avoid or increase…

201251002·December 21, 2012
Approved
PLR

PLR 201251001: IRS grants extra time to allocate generation-skipping transfer tax exemption

The IRS granted a settlor 120 days to allocate available generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The settlor had provided the relevant documents to an…

201251001·December 21, 2012
Approved
PLR

PLR 201250031: IRS declines to waive the 60-day IRA rollover requirement

The IRS declined to waive the 60-day rollover requirement for taxpayers who moved an IRA distribution into two non-IRA accounts before transferring the funds back to the IRA. The taxpayers said a…

201250031·December 14, 2012
Denied
PLR

PLR 201250030: IRS waives the 60-day IRA rollover requirement

The IRS waived the 60-day rollover requirement for a taxpayer who intended to transfer an IRA distribution to a rollover IRA, but whose bank deposited the funds into certificates of deposit and a…

201250030·December 14, 2012
Approved
DET

Determination 201250029: IRS denies exemption for a foreclosure-prevention organization

The IRS denied exemption under IRC section 501(c)(3) to an organization that proposed foreclosure-prevention counseling, mortgage-modification assistance, affordable-housing education, and related…

201250029·December 14, 2012
Denied
DET

Determination 201250028: IRS denies exemption for a foreclosure class-action organization

The IRS denied exemption under IRC section 501(c)(3) to an organization that planned to raise donations from foreclosure victims and finance a nationwide class-action lawsuit. The organization…

201250028·December 14, 2012
Denied
DET

Determination 201250027: IRS denies exemption for a foreclosure prevention organization

The IRS denied tax-exempt status under IRC section 501(c)(3) to an organization that proposed foreclosure prevention and mortgage counseling services. The organization charged clients upfront fees,…

201250027·December 14, 2012
Denied
PLR

PLR 201250026: IRS approved a private foundation's scholarship grant procedures

The IRS approved a private foundation's proposed scholarship program for graduating high school students who plan to attend an accredited four-year college or university in the United States or…

201250026·December 14, 2012
Approved
PLR

PLR 201250025: IRS approves a health information exchange's related activities

The IRS ruled that a tax-exempt supporting organization could manage and facilitate a regional health information exchange and related performance-reporting program. The program combined health-plan…

201250025·December 14, 2012
Approved
PLR

PLR 201250024: IRS approves expanded membership for a voluntary employees' beneficiary association

The IRS ruled that a voluntary employees' beneficiary association (VEBA) could add common-law employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership. The…

201250024·December 14, 2012
Approved
PLR

PLR 201250023: IRS approves expanded membership for a voluntary employees' beneficiary association

The IRS ruled that a voluntary employees' beneficiary association (VEBA) could add common-law employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership. The…

201250023·December 14, 2012
Approved
CCA

CCA 201250022: Chief Counsel addresses stock-for-debt exchanges and unpaid loss deductions

Chief Counsel advice addressed the federal tax treatment of insolvent insurance subsidiaries that exchanged stock for debt in state insolvency proceedings. The advice concluded that…

201250022·December 14, 2012
Advice
PLR

PLR 201250021: IRS approves supplemental stock-for-stock reorganization rulings

The IRS issued supplemental rulings for a proposed acquisition in which Target shareholders would exchange their stock solely for voting stock of Controlled 11. The ruling addressed related debt…

201250021·December 14, 2012
Approved
CCA

CCA 201250020: Chief Counsel addresses disclosure of captive insurance records

Chief Counsel advice addressed whether the IRS may use return information from one taxpayer's examination in examinations of unrelated taxpayers participating in a substantially similar captive…

201250020·December 14, 2012
Advice
PLR

PLR 201250019: IRS treats mixed-use senior living facilities as qualified health care property

The IRS ruled that a real estate investment trust's mixed-use senior living communities were health care facilities under IRC section 856(e)(6)(D)(ii). The communities included independent living,…

201250019·December 14, 2012
Approved
PLR

PLR 201250018: IRS grants extra time to make a qualified subchapter S subsidiary election

The IRS granted a corporation an additional 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary, or QSub. The corporation had intended the election to take…

201250018·December 14, 2012
Approved

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.