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 1239014: IRS approves a private foundation's research grant procedures
A private foundation sought advance approval for a program providing research grants to students, scholars, and historians studying the career and contributions of a redacted former senator. The IRS…
PLR 1239013: IRS grants a nonprofit hospital conditional pension funding waivers
A nonprofit critical access hospital requested waivers of the minimum funding standard for its pension plan after financial losses reduced its liquid assets and threatened its ability to meet…
PLR 1239012: IRS grants a nonprofit more time to revoke its lobbying election
An exempt public charity asked for more time to retroactively revoke its IRC § 501(h) lobbying election after becoming the sole member of an affiliated group. The organization said it had relied on…
IRS denies unusual-grant treatment for a recurring donor's facility grant
The IRS considered a nonprofit animal clinic's request to treat a proposed grant from a longtime major donor as an unusual grant. The donor had founded the organization, contributed substantial…
CCA 1239010: CCA explains the limitation period for partnership items
Chief Counsel advice addressed whether the period described in IRC § 6229(a) is a separate statute of limitations for a partnership. The advice stated that the § 6229(a) period is the partner's §…
CCA 1239009: CCA addresses privilege claims for advisory opinions
Chief Counsel advice addressed whether advisory opinions are automatically protected in their entirety. The advice stated that parts of the opinions may be covered by the attorney-client or attorney…
CCA 1239008: CCA distinguishes contiguous-property and enhancement rules
Chief Counsel advice addressed whether the enhancement rule should also apply when property is being valued under the contiguous-property rule for a conservation contribution. The advice stated that…
CCA 1239007: CCA addresses notice requirements for nominee and alter-ego levies
Chief Counsel advice addressed collection notices when the IRS files a notice of federal tax lien in the name of a nominee or alter ego, or plans to levy property titled in that name. It stated that…
CCA 1239006: CCA identifies who may be a REIT tax matters partner
Chief Counsel advice addressed the treatment of real estate investment trusts as partnerships for purposes of subtitle F of the Code, including the TEFRA procedures. It stated that under Treas. Reg.…
PLR 1239005: IRS grants more time to elect treaty deferral for Canadian RRSP earnings
Two taxpayers who moved from Canada to the United States maintained Canadian registered retirement savings plans and did not timely elect to defer U.S. income taxation on the plans' accrued earnings…
PLR 1239004: IRS denies late trader mark-to-market election
A liquidated subsidiary asked the IRS to treat its use of mark-to-market accounting as substantial compliance with the IRC § 475(f) trader election requirements. In the alternative, it requested…
PLR 1239003: IRS approves two type F reorganizations before an asset sale
A domestic parent asked the IRS to approve a restructuring involving a domestic subsidiary, a foreign subsidiary, and two newly formed foreign companies. In the first reorganization, the existing…
PLR 1239002: IRS approves a revised nuclear decommissioning funding schedule
A taxpayer that owned an interest in a nuclear power plant requested a revised schedule of ruling amounts for its nuclear decommissioning fund after the plant's operating license was extended. The…
PLR 1239001: IRS reinstates an S corporation election after an inadvertent missed ESBT election
A company treated as an S corporation transferred its stock to a trust that otherwise qualified as an electing small business trust, but the trustee did not timely file the required ESBT election.…
Determination 1238032: IRS revokes an organization's tax-exempt status after network marketing and private-benefit findings
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3), effective from the organization's stated start date. The determination says the organization was engaged in network…
PLR 1238031: IRS rules OTCBB-traded preferred stock is not publicly traded employer securities
A company asked whether a class of its preferred stock, traded on the OTC Bulletin Board, counted as publicly traded employer securities for the diversification rules of IRC § 401(a)(35). The IRS…
PLR 1238030: IRS approves a pension-plan amendment with only a de minimis liability increase
A multiemployer defined benefit plan asked whether an amendment that would let certain pensioners continue working without permanently suspending their benefits was reasonable and caused only a de…
PLR 1238029: IRS waives the 60-day IRA rollover deadline after custodian errors
An individual asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The IRS found that errors by custodians caused the funds to be placed in a non-IRA joint…
CCA 1238028: Chief Counsel addresses tax assessments and fraudulent failure-to-file penalties
Chief Counsel advised that the Service could not reverse an abatement of tax assessed under a substitute for return after the collection limitations period had expired. It could assess additional…
CCA 1238027: State property classifications do not control federal like-kind exchange treatment
Chief Counsel advised that federal tax law, not state law alone, controls whether exchanged property is of like kind under IRC § 1031. State classifications as real or personal property are…
CCA 1238026: Fraud by an S corporation does not extend the assessment period for an uninvolved shareholder
Chief Counsel advised that a fraudulent Form 1120S filed by an S corporation does not extend the assessment period for an individual shareholder who did not participate in the fraud. The advice…
CCA 1238025: Taxpayer qualified as a securities dealer for mark-to-market purposes
Chief Counsel advised that an investment-bank holding company qualified as a dealer in securities under IRC § 475 because it regularly bought trust preferred securities from regional banks and sold…
PLR 1238024: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238023: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238022: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238021: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238020: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238019: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238018: IRS approves a tax-free split-off and related S corporation reorganization
The IRS approved a proposed transaction in which an S corporation would transfer about half of its assets to a wholly owned QSub, distribute the QSub stock to one shareholder in exchange for that…
PLR 1238017: IRS preserves S corporation status after defective trust elections
The IRS ruled that a corporation's S election was ineffective at first because several shareholder trusts were not eligible shareholders or had made the wrong type of election. It also ruled that…
PLR 1238016: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a personal representative 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases…
PLR 1238015: IRS preserves S corporation status after a late QSST election
The IRS ruled that an S corporation's election was inadvertently terminated when a trust failed to make a timely QSST election after the death of the original trust owner. The corporation could…
PLR 1238014: IRS preserves S corporation status after a late QSST election
The IRS ruled that an S corporation's election was inadvertently terminated when a trust failed to make a timely QSST election after the death of the original trust owner. The corporation could…
PLR 1238013: IRS approves refined-coal testing for an emissions tax credit
The IRS ruled that coal treated with the taxpayer's chemical process could qualify as refined coal for the IRC § 45 credit, provided the resulting fuel met the required emissions-reduction test and…
PLR 1238012: IRS grants extra time for a 2010 decedent's basis election
The IRS granted the executors of an estate 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis…
PLR 1238011: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a trustee 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases to be allocated…
PLR 1238010: IRS approves a revised nuclear decommissioning funding schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's share of the costs of decommissioning a nuclear power plant. The schedule used an independent study that reflected an extension…
PLR 1238009: IRS grants extra time for a taxable REIT subsidiary election
The IRS granted a company and its subsidiary 60 days to file a corrected Form 8875 and make an election to treat the subsidiary as a taxable REIT subsidiary, effective as of the requested date. The…
PLR 1238008: IRS restores S corporation and QSub status after an inadvertent trust-related termination
An S corporation's sole shareholder transferred the corporation's voting stock to a grantor trust and later died. The corporation's S election terminated when the trustees did not make an election…
PLR 1238007: IRS grants late-election and inadvertent-termination relief for an S corporation
The taxpayer intended for a corporation to be treated as an S corporation, but its parent was an ineligible S corporation shareholder and Form 2553 was not timely filed. The parent later distributed…
PLR 1238006: IRS grants a late S corporation election
The corporation intended to be treated as an S corporation but did not timely file Form 2553. It asked the IRS to recognize the S election from the intended effective date. The IRS found reasonable…
PLR 1238005: IRS grants extra time for a Canadian RRSP treaty election
The taxpayer, a Canadian citizen living permanently in the United States, held a Canadian Registered Retirement Savings Plan. The taxpayer and spouse had not made the election required to defer U.S.…
PLR 1238004: IRS approves a two-trust division and related tax treatment
The IRS approved a proposed division of an irrevocable trust into two separate trusts, one for each of the settlor's children and that child's descendants. The ruling concluded that the division…
PLR 1238003: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238002: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238001: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
IRS determination 1237029: Five-year amortization extension for a multiemployer plan
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The extension applies to the eligible amortization charge base established as…
PLR 1237028: IRS waives the 60-day rollover deadline after adviser error and illness
An IRA beneficiary received a distribution after her spouse's death and intended to roll part of it into a qualified IRA annuity. A financial adviser accidentally marked the annuity as…
PLR 1237027: IRS waives the 60-day rollover deadline after custodian errors
An IRA custodian distributed a taxpayer's retirement assets after it stopped serving as custodian, and another financial institution converted the account and its investments without the taxpayer's…
PLR 1237026: IRS waives the 60-day rollover deadline after IRA communication errors
The taxpayer received distributions from two inherited IRAs after the death of her spouse. She intended to move the funds into IRAs in her own name, but communications with a financial institution…
PLR 1237025: IRS waives the 60-day rollover deadline after financial-adviser error
The taxpayer received a distribution from her deceased spouse's individual retirement annuity and deposited it into a non-IRA account after her long-time financial adviser incorrectly concluded that…
IRS determination 1237024: Five-year multiemployer plan amortization extension
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The extension applies to the eligible amortization charge bases established as…
IRS determination 1237023: Private foundation set-aside approved for hospice-house construction
The IRS approved a private foundation's request to set aside funds for construction of a freestanding hospice house. The project was expected to require several years of planning, fundraising,…
IRS revokes a veterans organization's section 501(c)(19) exemption
The IRS revoked a veterans organization's tax exemption under section 501(c)(19), effective on the stated date. The determination also revoked the organization's group exemption and said that its…
IRS denies business league exemption under section 501(c)(6)
The IRS denied tax-exempt status to an organization that planned to provide referrals and other services to businesses in a specialized industry. The organization’s founder also controlled a…
IRS revokes an organization's section 501(c)(3) exemption for bingo activity
The IRS revoked an organization’s section 501(c)(3) exemption effective on the stated date. The organization’s primary activity was conducting weekly bingo games and selling pull-tabs, while its…
IRS denies exemption to a job-training organization with commercial operations
The IRS denied section 501(c)(3) exemption to an organization that offered fee-based interview, career, coaching, and online training programs. The organization’s founders also controlled a…
CCA 1237018: CCA addresses OFAS access to ARRA grant information
Chief Counsel advice considered whether the Treasury Department’s Office of the Fiscal Assistant Secretary could access IRS return information while administering the ARRA section 1603…
CCA 1237017: CCA addresses liabilities in an S corporation liquidation
Chief Counsel advice considered an S corporation that distributed assets subject to liabilities in a complete liquidation. The advice concluded that the liabilities are considered in calculating the…
PLR 1237016: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file Form 2553 to elect S corporation status. Based on the facts and representations submitted, the IRS found reasonable cause for the late…
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.