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
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PLR

PLR 201244004: IRS approves liquidating-trust and partnership-termination treatment

A limited partnership sold its assets and wanted to distribute the proceeds and dissolve, but it faced known and possible contingent liabilities. It formed a trust to hold cash, resolve those…

201244004·November 2, 2012
Approved
PLR

PLR 201244003: IRS grants more time for a PFIC mark-to-market election

A regulated investment company failed to identify two foreign corporations as passive foreign investment companies and did not make the IRC § 1296 mark-to-market elections for the prior tax year.…

201244003·November 2, 2012
Approved
PLR

PLR 201244002: IRS grants relief for an inadvertent S-corporation termination

An S corporation transferred shares to three trusts, but the trustees did not timely make the required elections to treat the trusts as electing small business trusts. The corporation represented…

201244002·November 2, 2012
Approved
PLR

PLR 201244001: IRS grants more time for a disregarded-entity election

A foreign eligible entity failed to timely file Form 8832 to elect classification as a disregarded entity for federal tax purposes, effective from its formation date. The IRS granted the entity 120…

201244001·November 2, 2012
Approved
PLR

PLR 201243021: IRS waives excise tax for late notices to alternate payees and unions

A company froze future pension benefit accruals and gave the required notices to affected employees, but not to certain alternate payees and unions. The company said it relied on experienced pension…

201243021·October 26, 2012
Approved
DET

IRS grants a five-year amortization extension for a multiemployer plan

The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a multiemployer plan. The extension applied to eligible amortization charge bases…

201243020·October 26, 2012
Approved
PLR

PLR 201243019: IRS declines to waive the 60-day IRA rollover deadline

An older taxpayer withdrew money from an IRA to secure an assisted-living arrangement while waiting for her home to sell. The home sold after the 60-day rollover period, and the distributed amount…

201243019·October 26, 2012
Denied
PLR

PLR 201243018: IRS waives the 60-day IRA rollover deadline because of mental impairment

An IRA owner withdrew part of a distribution after a divorce settlement and missed the 60-day rollover deadline. The taxpayer submitted medical documentation that a worsening mental condition…

201243018·October 26, 2012
Approved
PLR

PLR 201243017: IRS approves Roth IRA treatment for an airline employee's estate and surviving spouse

The estate of a deceased airline employee received pension distributions that qualified for special rollover treatment under section 125 of WRERA. The IRS concluded that the estate could transfer…

201243017·October 26, 2012
Approved
PLR

PLR 201243016: IRS waives the 60-day rollover deadline after an advisor's account-number error

A taxpayer intended to transfer a distribution from her late husband's profit-sharing plan into an IRA. Her financial adviser entered the account number for a non-IRA account instead, so the…

201243016·October 26, 2012
Approved
PLR

PLR 201243015: IRS approves a private foundation's transfer of property to a related foundation

A private foundation planned to transfer real and personal property worth more than 25 percent of its assets to a related organization, Project, which was expected to qualify as a private operating…

201243015·October 26, 2012
Approved
CCA

CCA 201243014: Chief Counsel advises on consolidated net operating loss carrybacks

Chief Counsel reviewed advice about an unclaimed consolidated net operating loss carryback and agreed that the identified consolidated net operating loss should not be included in calculating…

201243014·October 26, 2012
Advice
CCA

CCA 201243013: Chief Counsel analyzes netting of intercompany asset sales

Chief Counsel analyzed whether allocating the total price from an intercompany sale equally among assets with different values and useful lives could distort a consolidated group's depreciation…

201243013·October 26, 2012
Advice
PLR

PLR 201243012: Estate receives more time to complete a QDOT rollover and related filings

The IRS ruled for an estate whose surviving spouse was not a United States citizen and whose estate tax return made a qualified domestic trust (QDOT) election for a retirement account. The estate…

201243012·October 26, 2012
Approved
PLR

PLR 201243011: IRS denies late election for a low-income housing credit project

The IRS denied a taxpayer's request for more time to elect the month used to determine the applicable percentage for a low-income housing credit project financed with tax-exempt bonds. The taxpayer…

201243011·October 26, 2012
Denied
PLR

PLR 201243010: Trustee receives more time to make a 2010 basis election

The IRS granted a trustee 120 days to file Form 8939 and make the Section 1022 Election for property acquired from a decedent who died in 2010. The decedent's assets were held in a revocable trust,…

201243010·October 26, 2012
Approved
PLR

PLR 201243009: IRS preserves an S corporation election after a trust missed an ESBT election

The IRS granted relief to a corporation whose S corporation election was ineffective because a trust holding its stock did not qualify as a QSST and the trustees had not timely filed an ESBT…

201243009·October 26, 2012
Approved
PLR

PLR 201243008: IRS extends time to elect QSub treatment for three subsidiaries

The IRS granted an S corporation 120 days to file Forms 8869 and elect to treat three wholly owned subsidiaries as qualified subchapter S subsidiaries. The parent had intended to make the elections…

201243008·October 26, 2012
Approved
PLR

PLR 201243007: IRS extends time to elect QSub treatment for a subsidiary

The IRS granted an S corporation 120 days to file Form 8869 and elect to treat a wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the QSub election but…

201243007·October 26, 2012
Approved
PLR

PLR 201243006: IRS approves division of a pre-1985 generation-skipping trust

The IRS approved a proposed division of an irrevocable trust created before September 25, 1985 into four separate trusts for different family lines. It ruled that the divided trusts would retain…

201243006·October 26, 2012
Approved
PLR

PLR 201243005: IRS grants an LLC more time to elect corporate tax treatment

The IRS granted a business entity an extension of time to elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had converted from a corporation to a…

201243005·October 26, 2012
Approved
PLR

PLR 201243004: Estate gets relief for QTIP and GST elections and trust divisions

The IRS granted an estate 120 more days to make a QTIP election, divide a trust into exempt and non-exempt trusts, make a reverse QTIP election, and allocate the decedent's available GST exemption.…

201243004·October 26, 2012
Approved
PLR

PLR 201243003: Integrated hotel and apartment units may be one building for depreciation

The IRS ruled that a mixed-use development containing hotel rooms and residential apartments could treat its hotel and apartment condominium units as a single building when determining whether the…

201243003·October 26, 2012
Approved
PLR

PLR 201243002: Company gets relief for a late S corporation election

The IRS granted a company relief after it failed to timely file Form 2553 to elect S corporation status. The company had been incorporated in its state and intended the election to be effective on…

201243002·October 26, 2012
Approved
PLR

PLR 201243001: IRS declines to recognize a retroactive trust reformation

The IRS declined to recognize a state court's retroactive reformation of a trust for federal gift, estate, and generation-skipping transfer tax purposes. The reformation was intended to replace an…

201243001·October 26, 2012
Denied
DET

IRS approves a five-year amortization extension for a pension plan

The IRS approved a plan's request for a five-year automatic extension to amortize certain unfunded liabilities. The extension applied to eligible amortization charge bases established as of January…

201242026·October 19, 2012
Approved
PLR

PLR 201242025: IRS waives the 60-day rollover deadline after a bank error

The IRS waived the 60-day rollover requirement for a taxpayer who received a deceased spouse's IRA distribution and intended to roll it into her own IRA. She delivered the check to a financial…

201242025·October 19, 2012
Approved
PLR

PLR 201242024: IRS waives the 60-day rollover deadline after employer error

The IRS waived the 60-day rollover requirement for a taxpayer whose employer failed to follow written instructions to deposit a retirement-plan distribution into an IRA. The taxpayer entered the…

201242024·October 19, 2012
Approved
PLR

PLR 201242023: IRS waives the 60-day rollover deadline after a taxpayer misunderstood a 30-day account restriction

The IRS waived the 60-day rollover requirement for a taxpayer who withdrew assets from an IRA and put them into a non-IRA money market account. The taxpayer believed, based on advice from a…

201242023·October 19, 2012
Approved
PLR

PLR 201242022: IRS waives the 60-day rollover deadline after a financial institution misdirected a distribution

The IRS waived the 60-day rollover requirement for a taxpayer whose financial institution deposited an IRA distribution into the wrong account. The taxpayer had sent instructions that amounts from…

201242022·October 19, 2012
Approved
PLR

PLR 201242021: IRS waives the 60-day rollover deadline after a taxpayer misunderstood a 30-day account restriction

The IRS waived the 60-day rollover requirement for a taxpayer who withdrew assets from an IRA and put them into a non-IRA money market account. The taxpayer believed, based on advice from a…

201242021·October 19, 2012
Approved
PLR

PLR 201242020: IRS approves tax treatment of spun-off employer stock in a retirement plan

The IRS addressed a qualified defined contribution plan that received shares of a subsidiary when the employer spun off that subsidiary. The IRS ruled that the subsidiary shares continued to qualify…

201242020·October 19, 2012
Approved
PLR

PLR 201242019: IRS approves stock treatment after a workforce transfer and corporate spin-off

The IRS addressed two retirement plans after a corporate reorganization and the transfer of employees from one company to another. It ruled that shares transferred from the original plan to the new…

201242019·October 19, 2012
Approved
PLR

PLR 201242018: IRS grants more time to recharacterize invalid Roth IRA conversions

The IRS granted a married couple up to 60 days to recharacterize Roth IRA conversions that were not permitted because their modified adjusted gross income exceeded the applicable limit. The couple…

201242018·October 19, 2012
Approved
DET

IRS denies a new section 501(c)(3) exemption application over commercial activity and private inurement

The IRS issued a final adverse determination denying an organization's new application for exemption under IRC § 501(c)(3). The organization described housing, counseling, and other services, but…

201242017·October 19, 2012
Denied
DET

IRS denies section 501(c)(6) exemption to an association serving individual business interests

The IRS issued a final adverse determination denying exemption under IRC § 501(c)(6) to an association formed to serve health-care professionals. The association was controlled by one founder and…

201242016·October 19, 2012
Denied
DET

IRS denies section 501(c)(3) exemption to a mentoring organization tied to a related LLC

The IRS issued a final adverse determination denying tax exemption under IRC § 501(c)(3) to a nonstock corporation formed to mentor underachieving students and provide related support services. The…

201242015·October 19, 2012
Denied
DET

IRS denies section 501(c)(3) exemption to an Orthodox Jewish congregation

The IRS issued a final adverse determination denying tax exemption under IRC § 501(c)(3) to an Orthodox Jewish congregation that sought recognition as a church. The IRS found that the organization…

201242014·October 19, 2012
Denied
PLR

PLR 201242013: IRS approves a foundation’s cancer research grants to individual researchers

The IRS approved a private foundation's proposed grants to individual doctors and scientists conducting research on cancer treatments, with an emphasis on pediatric and anal cancers. The foundation…

201242013·October 19, 2012
Approved
PLR

PLR 201242012: IRS approves refined coal testing and feedstock rules for a production tax credit

The IRS approved four requested rulings for a refined-coal facility that uses a chemical process to reduce emissions from coal burned to produce electricity and steam. The ruling concludes that the…

201242012·October 19, 2012
Approved
CCA

CCA 201242011: Alaska municipalities are subject to wagering and occupational taxes

This Chief Counsel Advice concludes that Alaska municipalities are not agencies of a state for purposes of the wagering exemption in IRC § 4402(3). As a result, Alaska municipalities that engage in…

201242011·October 19, 2012
Advice
PLR

PLR 201242010: IRS grants more time for a consolidated 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 group had intended to make the…

201242010·October 19, 2012
Approved
PLR

PLR 201242009: IRS grants relief for an inadvertent S corporation election failure

The IRS granted relief to a corporation whose S corporation election was ineffective because a trust that acquired its stock did not make the required qualified subchapter S trust election. The IRS…

201242009·October 19, 2012
Approved
PLR

PLR 201242008: IRS grants a 60-day extension for a consolidated NOL election

The IRS granted a consolidated corporate group 60 days from the ruling date to make an election for an extended carryback period for a consolidated net operating loss. The group did not file a valid…

201242008·October 19, 2012
Approved
PLR

PLR 201242007: IRS approves a § 351 contribution followed by public offerings

The IRS approved a proposed transaction in which a partnership would transfer the assets and liabilities of a business group to a newly formed corporation in exchange for two classes of stock,…

201242007·October 19, 2012
Approved
PLR

PLR 201242006: IRS grants 120 days to make a QSub election

The IRS granted a parent corporation 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the subsidiary's stock, made an S…

201242006·October 19, 2012
Approved
PLR

PLR 201242005: IRS grants 120 days to elect out of automatic GST allocation

The IRS granted trustees 120 days to elect out of the automatic allocation of generation-skipping transfer tax exemption for five lifetime transfers to trusts benefiting the donor's grandchildren.…

201242005·October 19, 2012
Approved
PLR

PLR 201242004: IRS extends time for elections covering Canadian retirement plans

The IRS granted taxpayers 60 days to make elections under Rev. Proc. 2002-23 concerning Canadian registered retirement savings plans and registered pension plans. The taxpayers had moved from Canada…

201242004·October 19, 2012
Approved
PLR

PLR 201242003: IRS approves separate reverse exchanges using one titleholder

The IRS approved a proposed reverse like-kind exchange structure in which a taxpayer and a related affiliate would each enter into separate qualified exchange accommodation arrangements for the same…

201242003·October 19, 2012
Approved
PLR

IRS grants more time to sever a QTIP trust, make a reverse QTIP election, and allocate GST exemption

The IRS granted an estate additional time to divide a marital trust into exempt and non-exempt portions, make a reverse qualified terminable interest property (QTIP) election, and allocate the…

201242002·October 19, 2012
Approved
PLR

IRS grants extra time to file an IC-DISC election

The IRS granted a domestic corporation 60 additional days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation (IC-DISC). The corporation…

201242001·October 19, 2012
Approved
DET

IRS conditionally waives minimum funding requirements for a multiemployer plan

The IRS granted conditional waivers of the minimum funding standard for three plan years of a multiemployer pension plan. The plan covered employees subject to collective bargaining, had entered…

201241020·October 12, 2012
Approved
PLR

IRS treats an ESOP distribution as a lump-sum distribution eligible for NUA treatment

The IRS ruled that a participant's 2012 distribution of the entire account balance from an employee stock ownership plan would qualify as a lump-sum distribution under IRC § 402(e)(4). The…

201241019·October 12, 2012
Approved
DET

IRS revokes a social club's exemption because it lacked social activities and retained nonmember income

The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(7). The organization held title to and maintained a building used by four fraternal…

201241018·October 12, 2012
Revocation
PLR

IRS approves dividing inherited IRA assets among nine beneficiary IRAs

The IRS ruled that a trust named as the beneficiary of two IRAs qualified as a “see-through” trust, allowing the beneficiaries to be identified for required minimum distribution purposes. The…

201241017·October 12, 2012
Approved
PLR

IRS waives the 60-day rollover deadline after a financial institution miscalculated an RMD

The IRS waived the 60-day rollover deadline for an excess IRA distribution caused by a financial institution's failure to record the taxpayer's spouse's age. That error caused the institution to…

201241016·October 12, 2012
Approved
PLR

IRS waives the 60-day rollover deadline after a delayed replacement check

The IRS waived the 60-day rollover deadline for a taxpayer who could not deposit a retirement-plan distribution in time because a credit union delayed reissuing the check to the correct payee. The…

201241015·October 12, 2012
Approved
PLR

IRS waives the 60-day rollover deadline after a taxpayer's family hardships

The IRS waived the 60-day deadline for a taxpayer who took money from an IRA and intended to put it back, but missed the deadline while dealing with his brother's death and his sister-in-law's…

201241014·October 12, 2012
Approved
PLR

IRS approves a private foundation's employer-related scholarship program

The IRS approved a private foundation's program to award scholarships to eligible children of an employer's employees. An independent scholarship management company would administer applications,…

201241013·October 12, 2012
Approved
PLR

IRS approves surrender of tax-exempt status by an electric cooperative

The IRS ruled that a mutual or cooperative electric company exempt under IRC § 501(c)(12) could surrender its tax-exempt status and operate as a taxable cooperative by filing a final Form 990…

201241012·October 12, 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.