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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IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of April 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of March 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of August 1, 2009. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of January 1, 2009. The extension applies to amortization charge bases identified in the application…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan’s unfunded liabilities as of October 1, 2009. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of September 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established on that…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of May 1, 2010. The extension applies to eligible amortization charge bases identified in the…
IRS approves a five-year amortization extension for a plan
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2009. The extension applies to amortization charge bases identified in the application…
IRS approves a five-year amortization extension for a plan
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified in the…
PLR 201231020: IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS considered a taxpayer who received a distribution from an IRA intending to roll the funds into another IRA within 60 days. A financial institution mistakenly deposited the amount into a…
PLR 201231019: IRS waives the 60-day IRA rollover deadline after an annuity cancellation delay
The IRS considered a taxpayer who received an IRA distribution and invested it in an IRA annuity. Before annuity payments began, the taxpayer canceled the annuity, but the refund was delayed and the…
PLR 201231018: IRS waives the 60-day rollover deadline after an account was mistaken for an IRA
The IRS considered a taxpayer who received a distribution from a cash or deferred plan and intended to roll it into an IRA. The taxpayer and her spouse believed that an online account was an IRA,…
IRS revokes an organization's exemption after repeated failures to provide information
The IRS revoked an organization's tax-exempt status under IRC §§ 501(a) and 501(c)(3), effective January 1 of a redacted year. The IRS stated that the organization did not establish that it…
PLR 201231016: IRS grants more time for a private foundation election
The IRS granted a private foundation an extension of time to elect to treat prior-year excess qualifying distributions as current-year distributions out of corpus. The foundation had not made the…
PLR 201231015: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts with related charitable foundations as beneficiaries. The IRS ruled that the transfers would be…
PLR 201231014: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts while preserving the charitable and remainder interests described in its trust instrument. The IRS…
Written determination 201231013: IRS denies exemption to a single-brand franchisee association
The IRS issued a final adverse determination after a franchisee association did not protest a proposed adverse determination within 30 days. The association served franchisees of one restaurant…
Written determination 201231012: IRS denies exemption to a community wireless-network organization
The IRS issued a final adverse determination after a proposed denial of exemption was not protested within 30 days. The organization planned to provide free community Internet access through a…
CCA 201231011: Advice addresses accrual-method income from telephone excise-tax refunds
Chief Counsel advice addresses when an accrual-method business should recognize income from a telephone excise-tax refund. It states that income is generally recognized when all events fixing the…
CCA 201231010: U.S.-U.K. treaty advice addresses pension rollovers
Chief Counsel advice considers whether a U.K. resident could transfer funds from a U.S. pension scheme to a U.K. pension scheme without current U.S. tax. The advice concludes that Article 18(1) of…
PLR 201231009: IRS grants more time to elect corporate tax classification
A business entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The IRS concluded that the entity acted…
PLR 201231008: IRS grants more time to elect partnership classification
A foreign eligible entity asked for more time to file Form 8832 and elect partnership treatment for federal tax purposes. The IRS concluded that the entity had acted reasonably and in good faith and…
PLR 201231007: IRS rules that a testamentary power of appointment is not a general power
A daughter asked whether her testamentary power to appoint trust property among the settlors' issue would be treated as a general power of appointment under IRC § 2041. The IRS concluded that the…
PLR 201231006: IRS permits early reelection of the foreign earned income exclusion
An individual who had previously elected the foreign earned income exclusion asked to elect it again before the normal waiting period had ended. The individual had revoked the earlier election after…
PLR 201231005: IRS grants more time to elect corporate classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make the…
CCA 201231004: Chief Counsel analyzes accounting method changes and § 481(a) adjustments
Chief Counsel advice analyzed whether changing the time for deducting expenditures, or changing from deducting expenditures to capitalizing them, constitutes a change in method of accounting under…
PLR 201231003: IRS grants more time to file the 2010 estate basis election
The personal representative of an estate asked for more time to file Form 8939 and make the election under IRC § 1022 for an individual who died in 2010. A qualified tax professional had been…
PLR 201231002: IRS grants more time to allocate GST exemption to a trust
An individual asked for more time to allocate generation-skipping transfer tax exemption to a trust after the allocation was omitted from the individual's gift tax return. The individual had…
CCA 201231001: Chief Counsel approves a bond-backed collateral agreement in lieu of an NFTL
Chief Counsel considered whether the IRS could accept a collateral agreement secured by a bond instead of filing a Notice of Federal Tax Lien against a corporation that could not immediately pay its…
PLR 201230036: IRS approves a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The plan provided the required information and an actuary's certification that,…
PLR 201230035: IRS grants associated businesses a conditional pension funding waiver
Associated businesses asked the IRS to waive the minimum funding standard for a pension plan. The businesses were experiencing financial hardship after declining sales and profits, excess facility…
PLR 201230034: IRS denies a pension funding waiver because the hardship was not temporary
A mutual insurance company asked the IRS to waive the minimum funding standard for its pension plan. The company reported declining sales and revenue, but its interim financial statements showed…
PLR 201230033: IRS approves a five-year pension liability amortization extension
A pension plan asked the IRS for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The IRS approved the extension under IRC § 431(d)(1), effective for…
PLR 201230032: IRS waives the 60-day IRA rollover deadline for an elderly taxpayer
An elderly taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer represented that dementia and prior strokes impaired his memory and…
PLR 201230031: IRS confirms that a college pension plan is a church plan
A college asked the IRS whether its defined benefit pension plan qualified as a church plan under IRC § 414(e). The college was affiliated with a religious convention, shared its religious bonds and…
PLR 201230030: 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 201230029: 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 201230028: 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 201230027: 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 201230026: 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 201230023: 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 201230022: 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 201230021: 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 201230020: 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 201230019: 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…
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.