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 201230018: 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 201230017: 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 201230016: 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 201230015: 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 201230014: 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 201230013: 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 201230012: 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 201230011: 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 201230010: 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 201230009: 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 201230008: 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 201230007: 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 201230006: 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 201230005: 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 201230004: 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 201230003: 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 201230002: 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 201230001: 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 201229024: 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 201229023: 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 201229022: 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 201229021: 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 201229020: 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 201229019 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 201229018: 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 201229017: 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 201229016: 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 201229015: 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 201229014: 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 201229013: 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 201229012: 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 201229011: 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 201229009: 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 201229008: 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 201229007: 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 201229006: 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 201229005: 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 201229004: 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 201229003: 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 201229002: 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 201229001: 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 201228055: IRS allows return of pension surplus from an erroneous actuarial calculation
The IRS ruled that a terminated defined-benefit plan could return a premium refund to its sponsoring taxpayer after all plan liabilities were satisfied because the refund resulted from an erroneous…
PLR 201228054: 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 201228053: 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 201228052: 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 201228051: 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 201228050: 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 201228049: 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 201228048: IRS conditionally waives pension-plan excise taxes while closing a funding-waiver case
The IRS closed a company's request for a waiver of the minimum funding standard after the request was withdrawn. It separately granted conditional waivers of the 100 percent excise tax under IRC §…
PLR 201228047: IRS declines to waive the 60-day IRA rollover deadline
The IRS declined to waive the 60-day rollover requirement for an individual who withdrew stock from an IRA and did not complete the rollover on time. The taxpayer said an account representative…
PLR 201228046: IRS waives the 60-day IRA rollover deadline because of medical impairment
The IRS waived the 60-day IRA rollover requirement for a taxpayer who received a distribution and mistakenly deposited it into a non-IRA account. The taxpayer supported the request with medical…
PLR 201228045: IRS approves a limited lump-sum window for pension annuitants
The IRS ruled that two defined benefit plans could offer a limited window for certain participants and beneficiaries who had already begun receiving annuity payments to elect a lump-sum payment…
PLR 201228044: IRS waives the 60-day rollover deadline after an IRA owner was defrauded
The IRS waived the 60-day rollover requirement for an older taxpayer who was misled by an individual into transferring IRA funds to an account controlled by the individual and an associated company.…
PLR 201228043: IRS waives the 60-day rollover deadline for a late § 457(b) rollover
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from a governmental § 457(b) plan and transferred part of it to an IRA about a week late. The taxpayer…
IRS denies § 501(c)(3) exemption to an organization formed to benefit a related business
The IRS issued a final adverse determination denying an organization exemption under IRC § 501(c)(3). The organization was formed primarily to obtain grant funding for a related for-profit company,…
IRS denies § 501(c)(3) exemption to a water-conservation organization linked to a for-profit publisher
The IRS issued a final adverse determination denying a water-conservation organization exemption under IRC § 501(c)(3). The organization shared board control with a related for-profit publisher…
IRS denies § 501(c)(3) exemption to a mortgage-foreclosure counseling organization
The IRS issued a final adverse determination denying a mortgage-foreclosure counseling organization exemption under IRC § 501(c)(3). The organization proposed counseling and possible mortgage…
IRS grants a private foundation five more years to dispose of excess business holdings
The IRS granted a private foundation an additional five-year period to dispose of shares that constituted excess business holdings. The foundation had received a minority interest in a closely held…
IRS approves a scholarship competition and grant program for students
The IRS approved a private foundation’s proposed scholarship and grant-making program under IRC § 4945(g)(1). The program would select high-school students from several schools to give short…
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.