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 201250017: IRS rules that a subsidiary must file a separate return
The IRS ruled that a subsidiary had to file a separate federal income tax return for a specified tax year. The subsidiary had previously joined its parent's consolidated returns, but it later became…
PLR 201250016: IRS grants extra time to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as disregarded as an entity separate from its owner for federal tax purposes. The entity was…
PLR 201250015: IRS grants extra time to make a success-based fee safe harbor election
The IRS granted a taxpayer 45 additional days to attach the required statement for an election under Revenue Procedure 2011-29. The taxpayer used the safe harbor for allocating success-based fees…
PLR 201250014: IRS rules that specified partnership income is qualifying income
The IRS ruled that income a limited partnership expected to earn from marketing certain redacted mineral or natural-resource products would be qualifying income under IRC section 7704(d)(1)(E). The…
PLR 201250013: IRS grants relief for an inadvertent S election termination
The IRS ruled that a corporation's S election terminated when it transferred shares to a trust that was not an eligible S corporation shareholder. The corporation and its shareholders had not…
PLR 201250012: IRS grants extra time to make a section 754 election
The IRS granted a partnership an additional 120 days to make a section 754 election. The partnership had timely filed its tax return but omitted the written election statement required to adjust the…
PLR 201250011: IRS grants relief for a late S corporation election
The IRS ruled that a corporation could be recognized as an S corporation from its intended effective date even though it filed Form 2553 late. The corporation's shareholders had intended S…
PLR 201250010: IRS grants extra time for a worthless stock loss election
The IRS granted a corporate parent an additional 75 days to file a statement required to elect recognition of a loss on the disposition of subsidiary stock under Treas. Reg. § 1.337(d)-2(c). The…
PLR 201250009: IRS approves cooperative grain payments as per-unit retains
The IRS ruled that a farmers cooperative's planned cash payments to members and participating patrons for grain would qualify as per-unit retain allocations paid in money. The cooperative planned to…
PLR 201250008: IRS treats fixed timberland and easement payments as REIT-qualifying income
The IRS ruled that fixed initial rent and delay rent paid under mineral leases, along with payments for surface damage, seismic surveys, and temporary easements, would qualify as rents from real…
PLR 201250007: IRS approves a revised nuclear decommissioning funding schedule
The IRS approved a utility's revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The utility's nuclear plant license had been extended, so it updated its…
PLR 201250006: IRS approves a revised nuclear decommissioning fund schedule
The IRS approved a nuclear utility's revised schedule of ruling amounts for contributions to a decommissioning fund after the plant's operating license was extended. The utility based its proposed…
PLR 201250005: IRS voids an inadvertent GST exemption allocation
The IRS ruled that a taxpayer's allocation of available generation-skipping transfer tax exemption to a 2010 transfer to a trust was void. The taxpayer had retained a professional to prepare the…
PLR 201250004: IRS approves cross-border F and D reorganizations in an acquisition structure
The IRS approved the federal tax treatment of a proposed cross-border acquisition and restructuring involving a domestic parent, a foreign corporation, a new foreign acquirer, and multiple foreign…
PLR 201250003: IRS treats offshore platform lease income as qualifying income
The IRS ruled that income from leasing an offshore oil and gas platform would qualify as rents from real property for purposes of the publicly traded partnership income exception. The platform and…
PLR 201250002: IRS grants extra time to elect an extended NOL carryback
The IRS granted a consolidated group 60 days to file an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline while relying on a…
PLR 201250001: IRS treats a trust income interest as intangible property for gift tax purposes
The IRS ruled that a nonresident, noncitizen's release of income interests in several subtrusts would be treated as a transfer of intangible property and therefore would not be subject to gift tax…
PLR 201251021: IRS approved a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship program for graduating high school students and current college or graduate students. The scholarships could cover tuition, books,…
PLR 201251019: Ticket revenue from a seasonal literacy event was not unrelated business income
The IRS ruled that ticket revenue from a nonprofit's seasonal event based on a literary work was not unrelated business taxable income. The organization used the event to promote reading, literacy,…
PLR 201251024: IRS allowed a VEBA to add certain Indian tribal organization employees
The IRS ruled that a tax-exempt voluntary employees' beneficiary association could add eligible employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership.…
PLR 201251023: IRS allowed a VEBA to add certain Indian tribal organization employees
The IRS ruled that a tax-exempt voluntary employees' beneficiary association could add eligible employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership.…
PLR 201249018: IRS approves deductions for welfare benefit fund note payments
The IRS ruled on the tax treatment of a company's prepayment of a note contributed to a welfare benefit trust and the later transfer of that note to a third party. It concluded that qualifying…
Determination 201249017: IRS approves a private foundation scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to students at qualifying educational institutions. The foundation planned to select recipients through an objective…
Determination 201249016: IRS denies exemption for a free investment advice organization
The IRS upheld a denial of tax-exempt status for an organization that planned to provide free investment advice and financial literacy assistance. The organization’s articles authorized purposes…
CCA 201249015: IRS says gift tax underpayment interest starts on the original due date
Chief Counsel advised that underpayment interest on an unreported gift tax deficiency begins on the original due date of the gift tax return. The taxpayer made an earlier taxable gift without filing…
PLR 201249014: IRS permits a retroactive qualified electing fund election
The IRS consented to a domestic limited partnership's retroactive qualified electing fund, or QEF, election for an investment in a passive foreign investment company. The partnership had relied on…
PLR 201249013: IRS revokes a wind facility basis ruling
The IRS revoked an earlier private letter ruling about the tax basis of wind energy facilities acquired with facility-specific power purchase agreements. The earlier ruling had concluded that no…
PLR 201249012: IRS modifies a corporate separation ruling
The IRS supplemented an earlier private letter ruling on a series of corporate separations, reorganizations, distributions, and related transactions. The supplemental ruling changed which affiliated…
PLR 201249011: IRS approves a stock acquisition after a corporate spin-off
The IRS supplemented an earlier private letter ruling involving a corporate separation followed by an acquisition of a target company. The planned acquisition used a merger subsidiary, with target…
PLR 201249010: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated corporate group an extension of time to make an election for an extended carryback period for a consolidated net operating loss. The election had not been timely…
PLR 201249009: IRS allows a late S corporation election
The IRS allowed a corporation to make a late election to be treated as an S corporation. The corporation had intended the election to be effective on a specified date, but it did not timely file…
PLR 201249008: IRS grants more time for a partnership classification election
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had failed to timely file Form 8832, even though it was…
PLR 201249007: IRS extends time to file a consolidated return election
The IRS granted a new parent company more time to elect consolidated return treatment for a taxable year after a corporate acquisition and merger changed the affiliated group. The group had intended…
PLR 201249006: 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’s sole shareholder intended the election to be effective on a specified date, but the proper…
PLR 201249005: IRS grants more time to claim a worthless stock loss election
The IRS granted a consolidated group an extension of time to file statements needed to claim a worthless stock loss election for two subsidiaries. The subsidiaries' stock became worthless, but the…
PLR 201249004: IRS grants more time for an extended net operating loss carryback election
The IRS granted a consolidated group 60 more days to make an election for an extended carryback period for a consolidated net operating loss. The group missed the deadline for the election, which…
PLR 201249003: IRS grants more time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled entity 30 more days to elect to be treated as a taxable entity for purposes of the depreciation rules. The entity was a co-general partner in a low-income…
PLR 201249002: IRS approves charitable transfers involving a remainder unitrust
The IRS ruled that a surviving donor could transfer an undivided portion of a charitable remainder unitrust payment and the related trust remainder to the charitable remainder beneficiary. The donor…
PLR 201249001: IRS approves a revised nuclear decommissioning funding schedule
The IRS approved a revised schedule of ruling amounts for a regulated public utility's nuclear decommissioning fund. The schedule sets the annual amounts the taxpayer may pay into the fund and…
CCA 201248022: Chief Counsel addresses backup withholding for slot-machine winnings
Chief Counsel advised that a gaming establishment generally is not subject to backup withholding merely because a Form W-2G reports a name and taxpayer identification number mismatch for…
CCA 201248021: Chief Counsel says a levy reaches vested pension benefits
Chief Counsel advised that a federal tax levy can reach a taxpayer's vested pension-plan rights, including present and future payment rights and the right to choose a distribution form. In the…
CCA 201248020: Chief Counsel says RFRA does not bar a tax levy on a parsonage allowance
Chief Counsel advised that the Religious Freedom Restoration Act does not generally bar the IRS from applying tax laws and collection remedies, including an administrative levy against a parsonage…
CCA 201248019: Chief Counsel says proceeds for unwanted medical procedures qualify for exclusion
Chief Counsel advised that proceeds received by individuals who underwent unwanted medical procedures qualify for exclusion from gross income under section 104(a)(2). The memorandum based that…
CCA 201248018: Chief Counsel addresses a missed cancellation-of-debt election
Chief Counsel advised that a taxpayer generally must make the election required to use the cancellation-of-debt income deferral provision under Revenue Procedure 2009-37. If the taxpayer misses the…
CCA 201248017: Chief Counsel explains which partnership partners are bound by a settlement
Chief Counsel advised that a tax matters partner could bind certain partners through a partnership settlement only within the limits of section 6224 and its regulations. Notice partners had to sign…
CCA 201248016: Chief Counsel addresses post-CSED payments after a levy
Chief Counsel advised that when the IRS levies fixed and determinable payment rights before the collection statute expiration date, payments received after that date can still be applied to the…
PLR 201248015: IRS grants more time for an oil and gas intangible drilling cost election
The IRS granted an oil and gas joint venture 60 more days to elect to deduct intangible drilling costs. The partnership had not timely made the section 263(c) election for a taxable year, and it…
PLR 201248014: IRS grants more time for an oil and gas intangible drilling cost election
The IRS granted an oil and gas joint venture 60 more days to elect to deduct intangible drilling costs. The partnership had not timely made the section 263(c) election for a taxable year, and it…
PLR 201248013: IRS allows a late S corporation election
The IRS allowed a company to be recognized as an S corporation even though it did not timely file Form 2553. The company showed reasonable cause for the late election. The IRS made the relief…
PLR 201248012: IRS grants more time for CNOL carryback elections
The IRS granted a consolidated group more time to revoke an election waiving a net operating loss carryback and to elect an extended carryback period. The group missed the deadline after relying on…
PLR 201248011: IRS approves tax treatment for a public retiree health trust
The IRS ruled that a trust established by a political subdivision to fund retiree health benefits would have income excluded from gross income under IRC § 115(1). The trust's assets would come from…
PLR 201248010: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a U.S. limited partnership making a retroactive qualified electing fund election for its investment in a foreign corporation that may have been a passive foreign investment…
PLR 201248009: IRS permits a retroactive QEF election for a PFIC investment
The IRS consented to a U.S. limited partnership making a retroactive qualified electing fund election for its investment in a foreign corporation that may have been a passive foreign investment…
PLR 201248008: IRS approves changes to an installment obligation
The IRS ruled that changing an installment note's maturity date, obligor, and interest rate would not be treated as a disposition or satisfaction of the installment obligation. The note arose from…
PLR 201248007: IRS approves changes to an installment obligation
The IRS ruled that changing an installment note's maturity date, obligor, and interest rate would not be treated as a disposition or satisfaction of the installment obligation. The note arose from…
PLR 201248006: IRS rules that restructuring an installment note is not a disposition
An individual asked whether changing an installment note from an employee stock ownership plan transaction would trigger current tax recognition. The proposed changes would defer the maturity date,…
PLR 201248005: IRS grants more time for a foreign entity classification election
The IRS granted a foreign entity 120 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification but failed to…
PLR 201248004: IRS grants more time for a depreciation election
The IRS granted a utility company 60 more days to make an election for 100-percent additional first-year depreciation on certain components of a larger self-constructed property. The company had…
PLR 201248003: IRS grants more time to file an accounting method change form
The IRS granted a taxpayer 30 more days to file the original Form 3115 for an accounting method change involving bonus expenses. The taxpayer's advisor had filed a copy with the IRS but…
PLR 201248002: IRS approves revocation of a section 1504(d) election and related reorganization treatment
The IRS consented to a parent corporation's revocation of an election that treated a wholly owned corporation formed under contiguous-country law as domestic for federal tax purposes. The revocation…
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.