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 1246023: IRS grants more time to request a revised nuclear decommissioning schedule
The IRS granted a nuclear-power taxpayer 120 days to request a revised schedule of ruling amounts for a qualified nuclear decommissioning fund under IRC § 468A. The taxpayer had received an NRC…
PLR 1246022: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted the executrices of an estate 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in…
PLR 1246021: IRS grants more time for a section 338(g) election
The IRS granted a purchaser 45 days to file a late IRC § 338(g) election for the stock of four controlled foreign corporations. The purchaser acquired the stock through disregarded entities but…
PLR 1246020: IRS grants more time for QTIP severance and reverse election
The IRS granted an estate 120 days to sever a QTIP trust into a GST-exempt QTIP trust and a GST-nonexempt QTIP trust and to make a reverse QTIP election for the exempt trust. The original decedent's…
PLR 1246019: IRS grants relief for a late S corporation election
The IRS granted a corporation 120 days to file Form 2553 and make an S corporation election effective on its intended date. The corporation was formed under state law but did not timely file the…
PLR 1246018: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted an executor 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in 2010. The executor…
PLR 1246017: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted the executors of an estate 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in 2010.…
PLR 1246016: IRS grants relief for a late disregarded-entity election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity had…
PLR 1246015: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246014: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246013: IRS treats certain foreign-subsidiary inclusions as qualifying REIT income
The IRS ruled that certain Subpart F and passive foreign investment company inclusions of a publicly traded real estate investment trust would qualify as income under the REIT gross-income test. The…
PLR 1246012: IRS approves refined-coal credit treatment and emissions testing methods
The IRS ruled that a taxpayer's facility produces qualifying refined coal for purposes of the section 45 credit, provided the coal comes from the same source or rank as the tested feedstock and…
PLR 1246011: IRS approves a revised nuclear decommissioning reserve schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's nuclear decommissioning fund after the operating license for its plant was extended. The taxpayer showed that it had a…
PLR 1246010: IRS approves a revised nuclear decommissioning reserve schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's nuclear decommissioning fund after the Nuclear Regulatory Commission extended the plant's operating license. The taxpayer…
PLR 1246009: IRS approves an elective review of a nuclear decommissioning schedule
The IRS approved an elective review and revised schedule of ruling amounts for a taxpayer's nuclear decommissioning fund. The taxpayer held a qualifying interest in the plant, relied on an…
PLR 1246008: IRS grants relief for possible inadvertent S corporation terminations
The IRS addressed several shareholder transactions that might have created a second class of stock and terminated a corporation's S election. It ruled that any termination caused by life insurance…
PLR 1246007: IRS finds assessment bonds do not fail the private loan financing test
The IRS ruled that proposed assessment bonds used to help finance a new convention hall would not be treated as loans to a private company under the private loan financing test. The company would…
PLR 1246006: IRS grants relief for three late partnership elections
The IRS granted three foreign entities 120 days to file Form 8832 and elect partnership classification for federal tax purposes, effective on their intended dates. Each entity had failed to timely…
PLR 1246005: IRS allows alimony deduction but denies deduction for attorney fees
The IRS ruled that court-ordered rehabilitative alimony payments to a former spouse qualified as alimony and were deductible by the payor under sections 71 and 215. The ruling found that a…
PLR 1246004: IRS approves a trust power appointment without changing GST-tax exemption
The IRS ruled that a surviving spouse's failure to exercise a power of appointment did not create a constructive addition to a trust or change the GST-tax-exempt status of its assets. The IRS also…
PLR 1246003: IRS allows an estate charitable deduction for distributed S corporation receivables
The IRS ruled that an estate could claim a charitable deduction under section 642(c) for receivables distributed to it by an S corporation and then paid to, or permanently set aside for, a…
PLR 1246002: IRS restores an S election after an untimely QSST election
The IRS ruled that a corporation's S corporation election terminated when a grantor trust became ineligible as a shareholder after the deemed owner's death and the beneficiary failed to make a…
PLR 1246001: IRS grants late S corporation election relief for reasonable cause
The IRS ruled that a company had reasonable cause for failing to timely file Form 2553 to elect S corporation status. The company could file the completed form within 120 days after the ruling,…
PLR 1245029: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day rollover requirement for a taxpayer whose retirement-plan stock was mistakenly deposited into a non-IRA account by a financial institution. The taxpayer sold the stock…
PLR 1245028: IRS approves an employer-related scholarship program
The IRS approved a private foundation's employer-related scholarship program under section 4945(g)(1). The program awards one scholarship each year to qualifying graduating high school students who…
Written determination 1245027: IRS revokes an organization's tax exemption
The IRS revoked an organization's exemption under section 501(c)(3), effective January 1 of the redacted year. The organization operated an apartment complex and reported rental income as its only…
Written determination 1245026: IRS revokes a private foundation's tax exemption
The IRS revoked a private foundation's exemption under section 501(c)(3), effective January 1 of the redacted year. The foundation did not operate primarily for charitable or other exempt purposes,…
Written determination 1245025: IRS revokes a nonprofit organization's tax exemption
The IRS revoked a nonprofit organization's exemption under section 501(c)(3), effective January 1 of a redacted year. The organization raised money by working concession stands at sporting events…
Written determination 1245024: IRS revokes an inactive school's tax exemption
The IRS revoked a university preparatory school's exemption under section 501(c)(3), effective July 1 of a redacted year. The school had filed for bankruptcy, stopped conducting exempt activities,…
Written determination 1245023: IRS revokes an organization's tax exemption for missing records
The IRS revoked an organization's exemption under section 501(c)(3), effective July 1 of a redacted year. The organization did not provide all of the books, records, and other information needed to…
Written determination 1245022: IRS revokes an organization's exemption for inurement and missing records
The IRS revoked an organization's section 501(c)(3) exemption after finding that it paid personal expenses of its officers and did not keep adequate records to support the business purposes of its…
Written determination 1245021: IRS denies exemption for a commercial property arrangement
The IRS finalized its denial of exemption under section 501(c)(3) for a religious organization formed to own and lease a property used by other organizations. The organization conducted prayer…
PLR 1245020: IRS approves a split-off of a controlled corporation
The IRS ruled on a proposed transaction in which a holding company would transfer property rights to a controlled subsidiary, exchange shares with certain shareholders, and distribute all of the…
CCA 1245019: Seaplane flights did not qualify for the air transportation tax exemption
Chief Counsel Advice concluded that section 4261(i) did not exempt certain seaplane transportation payments from federal air transportation excise taxes. The provider's flights took off from and…
CCA 1245018: Imported leased trucks were subject to the section 4051 tax
Chief Counsel Advice concluded that a U.S. company's use of an imported truck leased from a foreign corporation was subject to the section 4051 retail excise tax. A temporary importation bond did…
PLR 1245017: IRS revokes a ruling on a public-sector retiree health trust
The IRS revoked an earlier private letter ruling that treated a trust funding retiree health benefits for a public-sector authority as having income excludible under IRC § 115. The IRS concluded…
PLR 1245016: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's personal…
PLR 1245015: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's executrix had…
PLR 1245014: IRS restores S corporation status after an inadvertent termination
The IRS ruled that a corporation's S corporation election was inadvertently terminated when its trust shareholders stopped qualifying as qualified subchapter S trusts. The corporation represented…
PLR 1245013: IRS grants a trust more time to make a section 1022 election
The IRS granted the personal representatives of a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The…
PLR 1245012: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The estate's personal representative…
PLR 1245011: IRS approves a revised nuclear decommissioning fund schedule
The IRS approved a taxpayer's revised schedule of ruling amounts for a nuclear decommissioning fund. The request followed an extension of the plant's nuclear operating license and updated…
PLR 1245010: IRS excludes mandatory retiree health contributions from employees' wages
The IRS ruled that mandatory employee contributions to a city's retiree health trust and retiree medical benefits account are treated as employer contributions and excluded from employees' gross…
PLR 1245009: IRS grants extra time to make an extended CNOL carryback election
The IRS granted a consolidated group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group had not timely filed the election because it…
PLR 1245008: IRS grants extra time to make a trust distribution election
The IRS granted a trust 120 additional days to make a section 663(b) election. The trust had distributed an amount during the first 65 days of a tax year and intended the distribution to be treated…
PLR 1245007: IRS approves the division of an irrevocable trust into three separate trusts
The IRS approved a proposed pro rata division of an irrevocable trust created before September 25, 1985, into three separate trusts for three grandchildren and their descendants. The ruling…
PLR 1245006: IRS approves grantor-trust treatment and a post-death basis adjustment
The IRS ruled that a foreign taxpayer would be treated as the owner of an irrevocable trust during the taxpayer's lifetime because the trust's income had to be paid to the taxpayer and its principal…
PLR 1245005: IRS grants extra time to amend a 2010 estate basis allocation
The IRS granted a decedent's personal representative 120 additional days to amend Form 8939 for a 2010 estate. The timely filed form had omitted basis allocations for closely held business…
PLR 1245004: IRS approves a disclaimer of the remaining balance of an IRA
The IRS ruled that a surviving spouse made a qualified disclaimer of the remaining balance of an inherited IRA. The spouse had received required minimum distributions for two months after the…
PLR 1245003: IRS rules that a Mexican land trust arrangement is not a trust for federal tax purposes
The IRS ruled that a Mexican land trust arrangement used to hold a condominium was not a trust for U.S. federal income tax purposes. The bank holding legal title had no duty to manage, maintain, or…
PLR 1245002: IRS treats an inadvertent S corporation termination as continuing
The IRS ruled that a corporation's S election terminated when one shareholder transferred stock to an ineligible partnership. The corporation promptly corrected the problem, and the IRS found that…
PLR 1245001: IRS treats an inadvertent S corporation termination as continuing
The IRS ruled that a corporation's S election terminated when one shareholder transferred stock to an ineligible partnership. The corporation promptly corrected the problem, and the IRS found that…
PLR 1244024: IRS waives the 60-day IRA rollover requirement after a bank account error
The IRS waived the 60-day rollover requirement for a taxpayer whose bank deposited an IRA distribution into an unrelated trust account instead of the requested IRA rollover account. The taxpayer…
PLR 1244023: IRS waives the 60-day IRA rollover requirement after an annuity was misidentified
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew funds from an IRA annuity after financial and tax advisors failed to identify the account as an IRA. The taxpayer believed…
PLR 1244022: IRS waives the 60-day rollover requirement after an advisor moved IRA funds into a non-IRA annuity
The IRS waived the 60-day rollover requirement for a surviving spouse whose financial advisor moved an IRA distribution into a non-IRA annuity. The advisor did not tell the taxpayer that one of the…
Written determination 1244021: IRS denies tax exemption to a proposed nonprofit benefiting its founder and a for-profit company
The IRS denied a nonprofit corporation's application for recognition of tax exemption under IRC § 501(c)(3). The organization did not provide enough information about its proposed activities or its…
PLR 1244020: IRS approves a private foundation's asset transfers with conditions
The IRS ruled on a private foundation's proposal to transfer about two-thirds of its assets to two related private foundations. The IRS concluded that the transfers would qualify under IRC §…
CCA 1244019: Prompt assessment conversion depends on the status of the TEFRA proceeding
Chief Counsel advised that a request for prompt assessment under IRC § 6501(d) converts partnership items only if the TEFRA proceeding is not yet complete. The advice states that the conversion does…
CCA 1244018: Late and incomplete Form 1045 filings do not support NOL carryback relief
Chief Counsel advised that a taxpayer was not entitled to relief on a claim to carry back a net operating loss. The Form 1045 deadline had passed, and the taxpayer's earlier filings each contained a…
CCA 1244017: Trusts cannot qualify for the individual real-estate-professional tests under section 469(c)(7)
Chief Counsel advised that a trust cannot satisfy the qualifying tests in IRC § 469(c)(7)(B) because those tests apply to individuals. The advice focused on the requirement that the taxpayer perform…
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.