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 1230030: IRS says a successor custodian does not change legacy 403(b) account status
A financial institution asked whether replacing the custodian of certain legacy § 403(b)(7) custodial accounts would change the accounts' status under Rev. Proc. 2007-71. The existing custodian…
PLR 1230029: IRS grants more time to recharacterize an ineligible Roth IRA conversion
A married couple asked the IRS for more time to recharacterize a traditional IRA conversion as a contribution to a traditional IRA after their income made them ineligible for the Roth IRA…
PLR 1230028: IRS waives the 60-day rollover deadline after erroneous financial advice
Two taxpayers asked the IRS to waive the 60-day deadline for rolling distributions from traditional IRAs into self-directed IRAs. They relied on a financial advisor who directed the distributed…
PLR 1230027: IRS waives the 60-day Roth IRA rollover deadline after a financial institution error
An individual received a distribution from a Roth IRA and intended to roll it into a new Roth IRA. A financial institution representative instead provided paperwork for a non-IRA account and…
PLR 1230026: IRS approves transfers of a private foundation's assets to two related foundations
A newly formed private foundation planned to transfer all of its assets to two other private foundations controlled by the same people, after receiving assets from a marital trust and charitable…
IRS denies exemption to a pain management clinic
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to a pain management clinic organized as a nonprofit corporation. The clinic charged patient fees for…
IRS denies exemption to a concession-staffing organization
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to an organization formed to raise money for youth and other charitable activities by staffing concession stands…
PLR 1230023: IRS grants more time to elect special-use valuation for farmland
The IRS granted an estate more time to elect special-use valuation for farmland included in a decedent's estate. The executor timely filed the estate tax return but omitted the election, and a…
TAM 1230022: Dyeing undyed diesel fuel is not a nontaxable use
The IRS analyzed whether a refinery operator could claim a payment for diesel fuel tax after dyeing undyed diesel fuel at a terminal. The IRS concluded that adding dye did not consume the fuel or…
PLR 1230021: IRS allows corrective treatment of advanced coal project credits without disallowance
A regulated electric utility received qualifying advanced coal project credits under IRC § 48A, but later had part of the credits reallocated to another facility owner. The utility also amortized…
PLR 1230020: IRS permits a transfer between bankruptcy liquidating trusts
The IRS issued a supplemental ruling for a corporation liquidating through several trusts after a bankruptcy-related dispute over asset proceeds. A court order allowed Trust C to sell stock and…
PLR 1230019: Association serving municipal supervisors qualifies for section 115 income exclusion
The IRS ruled that an association serving municipal supervisors could exclude its income from gross income under IRC § 115(1). The association conducted educational conferences, provided technical…
PLR 1230018: IRS grants time to withdraw an excess nuclear decommissioning-fund contribution
The IRS granted a utility 120 days to withdraw an excess contribution and related earnings from a qualified nuclear decommissioning fund. The utility had calculated a special transfer using the…
PLR 1230017: IRS approves exclusion for a public retiree health-benefit trust
The IRS ruled that a trust established by a town to provide health and welfare benefits to former town employees and their dependents could exclude its income from gross income under IRC § 115(1).…
PLR 1230016: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file Form 2553, the election to be treated as an S corporation. The corporation’s shareholders intended the election to take effect on the…
PLR 1230015: IRS grants relief for a late S corporation election
The IRS ruled that a corporation could receive relief for failing to timely file Form 2553, the election to be treated as an S corporation. The corporation was intended to be an S corporation…
PLR 1230014: IRS classifies a bankruptcy trust as a liquidating trust
The IRS ruled that a trust created under a Chapter 11 bankruptcy liquidation plan would be classified as a liquidating trust for federal income tax purposes. The trust was formed to liquidate and…
PLR 1230013: IRS grants more time for a foreign entity classification election
The IRS granted a group of foreign entities 120 days to file Form 8832 and elect to be treated as associations taxable as corporations for federal tax purposes. The entities intended to use that…
PLR 1230012: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect a deferral of U.S. income tax on earnings in a Canadian Registered Retirement Savings Plan under the U.S.-Canada Income Tax Treaty and Rev. Proc. 2002-23.…
PLR 1230011: IRS permits revocation of an election not to claim bonus depreciation
The IRS permitted a partnership to revoke its elections not to deduct 50-percent and 100-percent additional first-year depreciation for qualified property placed in service in two taxable years. The…
PLR 1230010: IRS grants more time for a foreign partnership election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the form timely for its…
PLR 1230009: IRS treats a requested life insurance benefit reduction as a new issuance
The IRS ruled that reducing the face amount of certain life insurance contracts at an owner’s request would be treated as an exchange that makes the contracts newly issued for…
PLR 1230008: IRS issues supplemental rulings on liabilities and warrants in a corporate separation
The IRS issued supplemental rulings for a tax-free corporate separation in which a business was contributed to a controlled corporation and the controlled corporation’s stock was distributed to the…
PLR 1230007: IRS approves a tax-free corporate split-off
The IRS ruled that a completed transaction qualified as a tax-free corporate separation under IRC §§ 368(a)(1)(D) and 355. The distributing corporation transferred one business to a newly formed…
PLR 1230006: IRS grants late-election relief for a change in tax year
The IRS granted a taxpayer's request to treat a late Form 1128 as timely filed. The form requested a change in the taxpayer's accounting period from a year ending December 31 to a year ending…
PLR 1230005: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to elect an extended carryback period for a consolidated net operating loss. The group missed the deadline because it relied on a…
PLR 1230004: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent intended to make the election but…
PLR 1230003: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent missed the deadline after relying…
PLR 1230002: IRS grants late election for tax-exempt controlled entity
The IRS granted a taxpayer permission to make a late election to avoid treatment as a tax-exempt entity for certain depreciation rules. The taxpayer was wholly owned by a tax-exempt housing…
PLR 1230001: IRS grants more time to elect disregarded-entity status
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. The entity intended to make the election effective on a…
IRS determination 1229024: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2008. The extension covers liabilities described in IRC…
IRS determination 1229023: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2009. The extension covers eligible amortization charge bases…
IRS determination 1229022: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of January 1, 2010. The extension covers eligible amortization charge…
IRS determination 1229021: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of July 1, 2009. The extension covers eligible amortization charge bases…
IRS determination 1229020: Five-year amortization extension approved for a multiemployer plan
The IRS approved a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of September 1, 2009. The extension covers eligible amortization charge…
IRS determination 1229019 replaces a prior ruling and approves a five-year amortization extension
The IRS issued a replacement ruling approving a request for a five-year automatic extension for amortizing a multiemployer plan's unfunded liabilities as of January 1, 2008. The extension covers…
PLR 1229018: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229017: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229016: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229015: IRS grants conditional pension funding waivers to a company's salaried and hourly plans
The IRS granted conditional waivers of the minimum funding standard for a company's Salaried and Hourly defined benefit plans. The company manufactured edible collagen casings and reported financial…
PLR 1229014: IRS waives the 60-day rollover requirement after a family death
The IRS waived the 60-day deadline for a taxpayer who received a distribution from an IRA and completed a rollover shortly after the deadline. The taxpayer represented that a family member's death…
PLR 1229013: IRS declines to waive the 60-day rollover requirement
The IRS declined to waive the 60-day rollover requirement for a taxpayer who withdrew funds from an IRA and deposited them into a joint checking account. The taxpayer said he misunderstood an…
PLR 1229012: IRS rules on contribution limits for two multiemployer defined contribution plans
The IRS addressed contribution and deduction limits for two separate qualified defined contribution multiemployer plans maintained under a collective bargaining agreement. For the annual-additions…
PLR 1229011: IRS extends the period to dispose of donor-advised fund excess holdings
The IRS granted a donor-advised fund an additional five-year period to dispose of excess business holdings received as a bequest. The fund held a minority interest in a closely held family company,…
PLR 1229009: IRS grants a 120-day extension to make a partnership § 754 election
The IRS granted a partnership an additional 120 days to make a § 754 election for a specified taxable year and later years. The partnership had relied on its tax advisor to make the election but…
PLR 1229008: IRS treats a roadside-assistance provider as an insurance company
The IRS ruled that a roadside-assistance provider qualified as an insurance company taxable under IRC § 831. The provider issued risk-based contracts requiring it to provide assistance after…
PLR 1229007: IRS rules rental income is not passive investment income for an S corporation election
The IRS ruled that rental income received by a corporation from commercial and rental real estate was not passive investment income under IRC § 1362(d)(3)(C)(i). The corporation provided extensive…
PLR 1229006: IRS grants more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to make the election effective…
PLR 1229005: IRS rules a testamentary trust power is not a general power of appointment
The IRS ruled that a beneficiary’s testamentary power to appoint trust property among the settlors’ issue was not a general power of appointment under IRC § 2041(b)(1). The power could not be…
PLR 1229004: IRS confirms treatment of a proposed ownership-change transaction under § 382
The IRS issued a supplemental ruling concerning a company’s proposed public offering, debt restructuring, and redemption transaction. The company asked whether the proposed transaction would affect…
PLR 1229003: IRS approves stripped-certificate treatment and fixed-investment-trust classification
The IRS approved a structure in which mortgage-backed REMIC Certificates could be deposited into an Exchange Trust and exchanged for multiple classes of Exchange Certificates. The IRS ruled that the…
PLR 1229002: IRS approves a foreign-company spin-off and related restructuring
A taxpayer proposed to separate two businesses through a spin-off involving foreign corporations, disregarded entities, and several subsidiaries. The IRS ruled that the contribution of assets to…
PLR 1229001: IRS grants extra time to waive a consolidated NOL carryback
The IRS granted a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group had intended to make the election…
IRS approves substitute mortality tables for specified pension plans
The IRS approved a request to use substitute mortality tables for the pension plans in a specified permissive group. The approval applies to the listed bargaining-unit and non-bargaining-unit male…
PLR 1228055: IRS allows return of pension surplus from an erroneous actuarial calculation
The IRS considered whether a terminated defined-benefit plan could return surplus assets to its sponsoring taxpayer after purchasing annuity contracts for all plan liabilities. It ruled that the…
PLR 1228054: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The extension was granted under IRC § 431(d)(1) after the plan submitted the required…
PLR 1228053: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
PLR 1228052: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
PLR 1228051: IRS approves a pension plan’s annuity settlement window
The IRS approved a pension plan amendment creating a one-time window for certain retirees and beneficiaries to exchange future annuity payments for a qualified annuity option or a lump-sum payment.…
PLR 1228050: IRS grants a five-year extension to amortize a pension plan’s unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan’s actuary certified that, without the extension, the plan would face an…
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.