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 1237015: IRS grants late QSub election relief
The IRS granted a corporation 120 days to make late elections treating four wholly owned subsidiaries as qualified subchapter S subsidiaries. The corporation had acquired the subsidiaries, failed to…
PLR 1237014: IRS grants late QSub election relief
The IRS granted a parent S corporation 120 days to make a late election treating its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the election,…
PLR 1237013: IRS approves correction of an over-allocation of housing credits
The IRS approved a state housing credit agency’s correction of an administrative error that caused an over-allocation of low-income housing tax credit amounts. The agency had double-counted certain…
PLR 1237012: IRS approves an accounting-method change for service liabilities
The IRS approved an accounting-method change for a corporation that acquired a subsidiary in a section 381 transaction. The parent and subsidiary had used different methods for deducting liabilities…
PLR 1237011: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days from the ruling date to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer…
PLR 1237010: IRS grants late extended carryback election relief
The IRS granted a consolidated group 60 days to file a late election for an extended carryback period for a consolidated net operating loss. The group had intended to make the election under section…
PLR 1237009: 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 submitted facts and representations, the IRS found reasonable cause for the late…
PLR 1237008: IRS approves refined-coal testing and qualification methods
The IRS approved several aspects of a refined-coal facility’s testing and qualification approach for the section 45 refined coal credit. The ruling accepted the use of a proprietary additive process…
PLR 1237007: IRS approves refined-coal testing and qualification methods
The IRS approved a refined-coal facility’s proposed process, coal sourcing, and testing methods for purposes of the section 45 refined coal credit. The ruling treated the additive process as capable…
PLR 1237006: IRS grants late IC-DISC election relief
The IRS granted a corporation 60 days to file Form 4876-A to elect IC-DISC status for its first taxable year. The corporation had filed the form one day late because of a clerical error and argued…
PLR 1237005: IRS excludes a municipal retiree-health trust’s income
The IRS ruled that income from a trust established by a city to fund health benefits for eligible retirees and their dependents was excludable from gross income under section 115(1). The trust was…
PLR 1237004: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer to defer current…
PLR 1237003: IRS grants extra time to file a duplicate accounting-method application
The IRS granted a corporation an extension of time to file a signed duplicate copy of Form 3115, Application for Change in Accounting Method, with the IRS Ogden office. The corporation's accounting…
PLR 1237002: Married taxpayers receive more time to elect Canadian RRSP tax deferral
The IRS granted a married couple 60 days to elect treaty treatment that defers U.S. tax on income accrued in their Canadian registered retirement savings plans, or RRSPs. The couple had moved to the…
PLR 1237001: Administrative dissolution does not terminate an S corporation election
The IRS ruled that a corporation's administrative dissolution under state law did not terminate its S corporation status because the business continued to operate and file federal S corporation…
PLR 1236039: IRS waives the 60-day IRA rollover deadline after a medical hardship
The IRS waived the 60-day deadline for a 78-year-old taxpayer to roll an IRA distribution into another IRA. The taxpayer said that surgery, medication, and resulting confusion impaired her ability…
PLR 1236038: IRS waives the 60-day IRA rollover deadline after a postal delay
The IRS waived the 60-day deadline for a taxpayer who mailed an IRA rollover check but whose contribution arrived four days late because of postal delays. The taxpayer had withdrawn funds from one…
PLR 1236037: IRS declines to waive the 60-day IRA rollover deadline after incorrect advice
The IRS declined to waive the 60-day rollover deadline for a taxpayer who withdrew two IRA distributions for anticipated medical expenses and later redeposited them after receiving incorrect advice…
PLR 1236036: IRS waives the 60-day IRA rollover deadline after fraudulent misrepresentations
The IRS waived the 60-day rollover deadline for a 33-year-old taxpayer whose IRA funds were transferred to a non-IRA account after fraudulent misrepresentations by an individual and a company. The…
PLR 1236035: IRS waives the 60-day rollover deadline after reliance on professional advice
The IRS waived the 60-day deadline for a taxpayer who moved a distribution from a former employer's 401(k) plan into a new plan that was later rescinded and found not to be a qualified plan. The…
PLR 1236034: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day rollover deadline after a financial institution mistakenly deposited an IRA annuity distribution into a non-IRA account. The taxpayer had instructed the institution to use…
IRS denies section 501(c)(3) exemption to a proposed religious sanctuary
The IRS denied tax-exempt status to an organization that planned to operate a religious sanctuary offering lodging, food, animal care, gardens, and produce sales. The organization did not describe…
PLR 1236032: Private foundation receives five more years to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings received through a QTIP trust. The foundation had sold most of the holdings but still owned a…
IRS approves a private foundation's four scholarship programs
The IRS approved a private foundation's procedures for four scholarship programs. The programs serve students seeking degrees or diploma programs, including single parents, non-traditional adult…
CCA 1236030: Advice addresses when partnership items converted after late notice
Chief Counsel advice addressed when partnership items converted after the IRS sent partner-level notices late. The advice states that the 150-day petition period runs from the date the FPAA is…
CCA 1236029: Advice addresses use of Form 870-LT for partner-level issues
Chief Counsel advice addressed whether Part II of Form 870-LT could be used instead of Form 870PT(AD) to resolve partner-level issues. The advice states that Part II is a separate agreement executed…
CCA 1236028: Advice addresses partner amended adjustment requests under TEFRA
Chief Counsel advice answered questions about amended adjustment requests by partners in a TEFRA partnership. It states that the partner-level IRC § 6501(a) period does not extend the IRC § 6227…
CCA 1236027: Advice addresses a statute extension consent after entity-status change
Chief Counsel advice addressed a consent extending the statute of limitations for a TEFRA partnership after a change in entity status. It states that the change does not affect the procedures…
CCA 1236026: Advice permits crediting an overpayment against proposed deficiencies
Chief Counsel advice addressed whether a taxpayer's overpayment could be applied to specified periods with proposed, but not yet assessed, tax deficiencies. The advice concludes that the request may…
CCA 1236025: Advice treats participating convertible preferred stock as common stock
Chief Counsel advice addressed whether voting convertible preferred stock should be treated as common stock when analyzing a redemption under IRC § 302(b)(2). The advice concludes that the stock…
PLR 1236024: 120-day extension granted to make an entity classification election
A foreign eligible entity asked for more time to file Form 8832 and elect partnership classification for federal tax purposes. The entity had intended the election to be effective on a specified…
PLR 1236023: Auction platform qualifies as a matching service for partnership interests
A broker-dealer and its affiliated bank proposed an electronic auction platform for buying and selling third-party limited partnership interests. The platform would be limited to accredited…
PLR 1236022: Charitable payments under an estate settlement are deductible
An estate asked whether payments to charitable organizations under a proposed settlement of a will contest would qualify for the federal estate tax charitable deduction. The will named the attorney…
PLR 1236021: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236020: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236019: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236018: Late S corporation election treated as timely
A corporation's sole shareholder intended to elect S corporation status effective on a specified date, but Form 2553 was not filed on time. The corporation asked the IRS to treat the election as…
PLR 1236017: Late Section 198 election treated as perfected
A corporate taxpayer deducted qualified environmental remediation expenditures but its tax preparer omitted the words “Section 198 Election” from the required schedules for two tax years. The…
PLR 1236016: 120-day extension granted for disregarded-entity election
A foreign company intended to elect disregarded-entity treatment for federal tax purposes but did not timely file Form 8832. The company asked for an extension of time to make the election effective…
PLR 1236015: IRS grants extra time to make an extended NOL carryback election
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 missed the election deadline while relying on a…
PLR 1236014: IRS approves a spin-off and related corporate reorganizations
A public company proposed a series of mergers, entity conversions, liquidations, asset contributions, and a spin-off to separate two business lines from a third. The IRS ruled that specified steps…
PLR 1236013: IRS grants extra time to elect research-cost amortization
The IRS granted a taxpayer 60 days to make a late election to amortize certain research and experimental expenditures over ten years. The election applied to expenditures from three redacted taxable…
PLR 1236012: IRS grants time to make a depreciation election
The IRS granted an S corporation 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the required election statement from its…
PLR 1236011: IRS grants partnership time to make a depreciation election
The IRS granted a limited liability company treated as a partnership 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the…
PLR 1236010: IRS grants time to make a machinery depreciation election
The IRS granted an S corporation 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the required election statement from its…
PLR 1236009: IRS grants late S corporation election relief
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The corporation established reasonable cause for the late election under IRC §…
PLR 1236008: IRS approves refined coal credit testing methods
The IRS ruled on four questions involving a refined coal facility that used chemical additives to reduce nitrogen oxide and mercury emissions. It concluded that the treated coal could qualify as…
PLR 1236007: IRS approves refined coal credit testing methods
The IRS ruled on four questions involving a refined coal facility that used chemical additives to reduce nitrogen oxide and mercury emissions. It concluded that the treated coal could qualify as…
PLR 1236006: IRS approves zero-value treatment of deferred offering costs for a REIT asset test
The IRS ruled that a newly formed corporation intending to elect REIT status could include deferred initial public offering costs on its GAAP balance sheet without failing the section 856 asset…
PLR 1236005: IRS approves qualifying income from natural-resource processing
The IRS ruled that income from a publicly traded partnership's conversion of a natural-resource feedstock into another product would be qualifying income under section 7704(d)(1)(E). The partnership…
PLR 1236004: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to file its S corporation election on time. It found reasonable cause under section 1362(b)(5) and allowed the election to be treated as timely made…
PLR 1236003: IRS upholds S corporation status after disproportionate distributions
The IRS ruled that a corporation's disproportionate distributions and later corrective distributions did not create a second class of stock or terminate its S corporation election. The corporation's…
PLR 1236002: IRS grants extra time for an estate's alternate valuation election
The IRS granted an estate additional time to make the alternate valuation election under section 2032. The estate's tax professionals had failed to advise the administratrix about the election, and…
PLR 1236001: IRS grants extra time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had inadvertently missed the…
PLR 1235030: IRS grants extra time to recharacterize Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize two Roth IRA conversions as traditional IRA contributions. The couple had converted traditional IRAs in 2009, when their income…
PLR 1235029: IRS treats an accidental duplicate IRA payment as no modification of substantially equal payments
The IRS ruled for a taxpayer who received a duplicate IRA distribution after one financial institution failed to stop payments as instructed. The taxpayer was already receiving substantially equal…
PLR 1235028: IRS letter addresses a requested waiver of the 60-day IRA rollover deadline
The taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer intended to move the money into another IRA investment, but a company employee…
PLR 1235027: IRS waives the 60-day IRA rollover deadline after a financial institution's error
The IRS waived the 60-day rollover deadline for a 60-year-old taxpayer whose financial advisor used the wrong account documents. The taxpayer intended to move money from an IRA into a new IRA, but…
PLR 1235026: IRS waives the 60-day IRA rollover deadline because of a medical condition
The IRS waived the 60-day rollover deadline for a 69-year-old taxpayer who said a neurological condition prevented her from managing her financial affairs. She had withdrawn money from an IRA…
PLR 1235025: IRS approves an employer-related scholarship grant program
The IRS approved a private foundation's program to award scholarships to dependent children of employees of related companies. The program uses an independent selection committee, academic…
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.