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 1140030: IRS grants time to file a qualified separate line of business election
A company asked for more time to file Form 5310-A and make a qualified separate line of business election for a testing year. The request arose after the company learned that a wholly owned…
PLR 1139012: IRS waived the 60-day IRA rollover deadline after an advisor's error
An individual used money distributed from an IRA to buy company stock after a financial advisor incorrectly said the investment could be made outside the IRA trustee's custody. The individual…
PLR 1139011: IRS allowed a minor beneficiary to roll recovered retirement funds into an inherited IRA
The taxpayer was a minor who inherited a deceased parent's qualified retirement plan, but the guardian took a taxable lump-sum distribution instead of arranging a direct transfer to an inherited…
Determination 1138053: IRS denied a pension plan's minimum funding waiver
The IRS denied a company's request to waive the minimum funding standard for its pension plan. Although the company was experiencing financial distress, the IRS concluded that the hardship was not…
PLR 1138052: IRS waived the 60-day rollover deadline after an advisor's error
An individual withdrew money from an IRA to invest in a hedge fund after a financial advisor incorrectly advised that the transaction would be a proper rollover. The individual did not learn that…
PLR 1138051: IRS waived the 60-day rollover deadline for two advisor-mishandled IRA transfers
Two spouses transferred amounts from their IRAs to accounts in a hedge fund after a financial advisor incorrectly advised that labeling the accounts as IRAs would make the transfers proper…
PLR 1136038: IRS waives the 60-day IRA rollover deadline
An IRA owner tried to move a distribution into another IRA investment but followed incorrect instructions from a financial advisor, causing the amount to be deposited into a non-IRA account. The IRS…
PLR 1136037: IRS waives the 60-day IRA rollover deadline
An IRA owner received a distribution and intended to roll it into another IRA, but a financial advisor deposited it into a non-IRA account. The IRS found that the missed 60-day deadline resulted…
PLR 1136036: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of June 1, 2010. The extension applied to the eligible amortization charge bases identified…
PLR 1136035: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2010. The extension applied to the eligible amortization charge bases identified…
PLR 1136034: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136033: IRS approves a conditional minimum-funding waiver
The IRS approved a conditional waiver of a plan's required minimum funding contribution for a plan year ending September 30, 2009. The waiver required timely quarterly contributions, later…
PLR 1136032: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of June 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136031: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of April 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136030: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2011. The extension applied to eligible amortization charge bases established…
PLR 1136029: IRS waives the 60-day IRA rollover deadline
An IRA owner received a distribution check and relied on a financial advisor to roll the amount into another IRA. The advisor instead deposited it into a non-IRA account, and the taxpayer did not…
PLR 1135035: IRS waives the 60-day IRA rollover period
Two taxpayers received IRA distributions and intended to roll the amounts into new IRAs within 60 days. A debilitating bacterial infection affected one taxpayer near the end of the rollover period,…
PLR 1135034: IRS waives the 60-day rollover period after account-classification errors
A taxpayer inherited an annuity that was incorrectly classified as a regular investment instead of an IRA. After a financial advisor recommended liquidating the annuity, the proceeds were deposited…
PLR 1134026: IRS waives the 60-day IRA rollover deadline after bank error
A taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer said bank representatives repeatedly advised her to wait to deposit the…
PLR 1134025: IRS waives rollover deadlines after financial advisor fraud
A taxpayer received distributions from two IRAs intending to place the funds into an IRA annuity. The taxpayer says a financial advisor unlawfully deposited the combined amount into the advisor's…
PLR 1133015: IRS waives the 60-day IRA rollover deadline
An individual missed the 60-day deadline to roll an IRA distribution into a new IRA after a bank employee gave incorrect information about the rollover period. The individual represented that the…
PLR 1133014: IRS waives the 60-day deadline for an IRA rollover
An individual received a partial IRA distribution and missed the 60-day rollover deadline after a financial advisor deposited the funds into a joint non-IRA account. The taxpayer represented that…
PLR 1132029: IRS approved a state retirement system's governmental excess benefit arrangement
The IRS ruled that a state retirement system's excess benefit arrangement qualified under section 415(m). The arrangement supplements benefits from a defined benefit plan when section 415(b) limits…
PLR 1132028: IRS approved a governmental excess benefit arrangement for state employees
The IRS ruled that a state retirement system's proposed excess benefit arrangement qualified under section 415(m). The arrangement supplements benefits from a defined benefit plan when section…
PLR 1131035: 60-day IRA rollover requirement waived after financial institution error
The IRS waived the 60-day rollover requirement for an older taxpayer whose retirement distribution was mistakenly deposited into a regular brokerage account instead of an IRA. The taxpayer had…
Determination 1131034: Minimum funding waiver denied as hardship was not temporary
The IRS denied a controlled group's request to waive the minimum funding standard for a pension plan. The company had liquidated assets, lacked employees, and faced a real estate downturn that…
PLR 1130017: IRS explained the taxable and excludible portions of pension annuity payments
A taxpayer receiving pension annuity benefits had previously transferred one-third of the contract's present value to an IRA. The taxpayer asked how employee contributions that had already been…
PLR 1130016: IRS denied a minimum funding waiver because the business hardship was not temporary
A company requested a waiver of the minimum funding standard for its pension plan for the year ending March 31, 2009. The IRS found that the company was experiencing significant financial distress,…
PLR 1130015: IRS approved a five-year extension for amortizing unfunded pension liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of July…
PLR 1130014: IRS denied a waiver of the 60-day IRA rollover requirement
A taxpayer withdrew funds from an IRA intending to roll them over, but redeposited the funds after the 60-day period. The taxpayer cited job loss, a house fire, financial pressure, and a pending…
PLR 1130013: IRS waived the 60-day IRA rollover requirement after emotional distress and divorce proceedings
An older taxpayer unintentionally transferred funds from an IRA to a non-IRA account while moving assets to a bank near a new residence. The taxpayer then experienced severe emotional distress,…
Determination 1129053: IRS approves a five-year extension for amortizing an employee plan's unfunded liabilities
The IRS approved a five-year automatic extension for a plan to amortize unfunded liabilities as of July 1, 2010. The extension applies to eligible amortization charge bases identified in the plan's…
Determination 1129052: IRS approves a five-year extension for amortizing an employee plan's unfunded liabilities
The IRS approved a five-year automatic extension for an employee plan to amortize unfunded liabilities as of January 1, 2010. The extension is effective for the plan year beginning January 1, 2010,…
Determination 1129051: IRS approves a five-year extension for amortizing an employee plan's unfunded liabilities
The IRS approved a five-year automatic extension for an employee plan to amortize unfunded liabilities as of September 1, 2010. The extension is effective for the plan year beginning September 1,…
PLR 1129048: IRS waives the 60-day IRA rollover deadline after an advisor's deposit error
The IRS waived the 60-day rollover requirement for an individual whose IRA distribution was mistakenly deposited into a non-IRA account. The taxpayer intended to roll the full distribution into…
PLR 1129047: IRS waives the 60-day IRA rollover deadline after an advisor's deposit error
The IRS waived the 60-day rollover requirement for an individual whose IRA distribution was mistakenly deposited into a joint non-IRA account. The taxpayer intended to roll the funds into another…
PLR 1129046: IRS waives the 60-day IRA rollover deadline after a financial institution's deposit error
The IRS waived the 60-day rollover requirement for an individual whose distribution from an IRA was mistakenly deposited into a non-IRA account. The taxpayer intended to use the funds to purchase a…
PLR 1129045: IRS waives the 60-day rollover deadline for two IRA distributions transferred to a grantor trust account
The IRS waived the 60-day rollover requirement for two IRA distributions that were mistakenly transferred into a standard non-IRA account maintained within a grantor trust. The taxpayer intended to…
PLR 1129044: IRS waived the 60-day rollover deadline after a retirement distribution was deposited into a non-IRA account
A taxpayer received a retirement-plan distribution that was intended for an IRA, but a financial advisor deposited it into a non-IRA account. The taxpayer later moved the remaining amount into an…
PLR 1129029: Contract receives annuity treatment without offsetting account losses
An insurance issuer proposed a contract tied to a customer's investment account that would provide a benefit if the account fell below a specified minimum, while also allowing permitted withdrawals…
PLR 1128036: IRS approves dividing an inherited IRA for two estate beneficiaries
The IRS ruled for an estate representative who sought to divide a deceased owner's IRA into two inherited IRAs for the owner's children. The IRS concluded that the proposed trustee-to-trustee…
PLR 1128017: IRS treats a guaranteed account benefit contract as an annuity
An insurance company asked how a proposed contract would be treated for federal tax purposes. The contract would charge a fee and provide a lifetime benefit if an investment account fell below a…
PLR 1127022: IRS waives the 60-day IRA rollover requirement
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from an IRA into another retirement account. The individual said that a spouse's serious medical condition,…
Determination 1127021: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127020: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127019: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127018: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
PLR 1126041: IRS declines to waive the 60-day IRA rollover requirement
A taxpayer received distributions from two IRAs and placed the funds into non-IRA certificates of deposit after relying on instructions from a financial institution representative. The taxpayer…
PLR 1125047: Surviving spouse may roll inherited IRA proceeds into her own IRA
A surviving spouse received an individual retirement account through an estate and trust structure after the account owner’s death. The IRS ruled that the account would not be treated as an…
PLR 1125009: Qualified disclaimer allowed for remaining retirement interests, but not received distributions
The IRS considered whether a surviving spouse's estate could disclaim retirement-account interests inherited after the spouse's death. The spouse had received required minimum distributions that…
PLR 1124031: IRS waives the 60-day IRA rollover deadline after an advisor's withholding error
The IRS waived the 60-day rollover requirement for excess tax withholdings from substantially equal periodic payments from three IRAs. The taxpayer said a financial advisor's administrative error…
PLR 1124030: Company stock qualifies as employer securities for an ESOP
The IRS ruled that an S corporation's common stock would qualify as employer securities for an employee stock ownership plan covering employees of the corporation's wholly owned LLC. The LLC had not…
PLR 1124008: IRS approves trust's annuity contract rulings
The IRS ruled on a trust's plan to buy flexible premium deferred annuity contracts for several individual beneficiaries. The contracts would be held by the trust during the life of the surviving…
PLR 1123049: IRS approves a five-year pension-plan amortization extension
The IRS approved a request for a five-year extension of the period for amortizing a pension plan's unfunded liabilities. The extension applies to the eligible amortization charge bases identified in…
PLR 1123048: IRS declines a late rollover waiver after the beneficiary's death
The IRS declined to waive the 60-day rollover requirement for a surviving spouse who sought to move her deceased husband's plan distribution into a tax-deferred account in her own name. The husband…
CCA 1123031: In-laws are outside the listed family-member categories for section 4975(e)(6)
This Chief Counsel Advice identifies the family members included for purposes of IRC § 4975(e)(6). It lists the IRA owner's spouse, ancestors, lineal descendants, and spouses of lineal descendants.…
PLR 1122034: IRS explains the taxable and nontaxable portions of pension annuity and lump-sum payments
An individual living outside the United States asked how pension annuity payments and a related lump-sum transfer to an IRA would be treated if the individual were a U.S. resident. The IRS treated…
PLR 1122032: IRS waives the 60-day rollover deadline after incorrect financial advice
Two retirees withdrew funds from their IRAs after their financial advisor told them they could roll the funds into their former employer's plan. The retirees later learned that they were no longer…
PLR 1122031: IRS waives the 60-day rollover deadline after a financial institution's distribution error
An individual received an IRA distribution that was larger than intended because a financial institution initiated the wrong amount. The individual returned the excess to the IRA, but the 60-day…
Determination 1121037: IRS modified funding conditions for a pension plan’s amortization extension
The IRS conditionally approved a request to modify the terms of an earlier ruling that allowed a pension plan to amortize unfunded liabilities over an extended period. It reduced the required…
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.