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 1105007: IRS approves refined-coal testing and credit treatment
A partnership planned to use a chemical technology to produce refined coal that reduced emissions from coal combustion. The IRS concluded that the treated coal could qualify as refined coal for the…
PLR 1105006: IRS approves refined-coal testing and credit treatment
A partnership planned to use a chemical technology to produce refined coal that reduced emissions from coal combustion. The IRS concluded that the treated coal could qualify as refined coal for the…
PLR 1105004: IRS approves tax treatment of a guaranteed withdrawal annuity
A taxpayer planned to purchase a certificate tied to selected assets in a managed account. The certificate allowed withdrawals and promised a guaranteed minimum lifetime benefit if the selected…
PLR 1105002: IRS approves refined coal treatment for an emissions-reducing technology
The IRS considered a partnership that would use a chemical additive technology to produce refined coal at a facility next to a utility station. The IRS ruled that coal treated with the technology…
PLR 1104061: IRS approves non-IRA payment of investment-advisory wrap fees
The IRS considered a securities broker-dealer and investment adviser that offered wrap-fee investment-advisory accounts to traditional IRA and Roth IRA holders. The fees covered recurring advisory,…
CCA 1104040: New construction may qualify for the long-time resident credit
Chief Counsel advised that a taxpayer who completed construction and occupied a new home on land where a previous home stood could qualify for the $6,500 first-time homebuyer credit as a long-time…
CCA 1104039: Advance bonus payments require a bona fide loan analysis
Chief Counsel identified the central issue in an arrangement involving advances made in anticipation of future employee bonuses: whether the advances were bona fide loans. The advice said the…
CCA 1104037: A storage dwelling was not the taxpayer's principal residence
Chief Counsel advised that a taxpayer whose home was destroyed by fire could qualify as a first-time homebuyer after constructing and occupying a new home on the same property. While building, the…
CCA 1104032: Service incentives are taxable, not student-loan exclusions
Chief Counsel advised that payments to health care professionals under two state programs were taxable compensation for services, not excludable student-loan repayments. Participants did not need…
PLR 1104029: Agencies received more time to make private-activity-bond carryforward elections
The IRS granted two state agencies an extension of time to file Form 8328 and carry forward unused private activity bond volume cap. The filing was late because the state was coordinating a new…
PLR 1104024: IRS approves correction of an over-allocation of low-income housing credits
A state housing agency asked to correct an administrative error that caused supplemental low-income housing tax credits to exceed the state's housing credit ceiling. The IRS concluded that the error…
PLR 1104020: Port authority does not qualify for tax-exempt bond treatment
A public corporation asked whether it qualified as a political subdivision for purposes of the tax exemption for interest on state or local bonds, or whether its debt was issued on behalf of a city.…
PLR 1104001: IRS approves a settlement dividing a family trust without added transfer tax
A family asked how a proposed court-approved settlement of long-running disputes over two trusts would affect income, gift, estate, and generation-skipping transfer taxes. The settlement divided one…
CCA 1103046: Counsel advises disallowing unsupported Schedule C income and expenses
Chief Counsel advised that Schedule C income and expenses should be fully disallowed when the activity does not qualify as carrying on a trade or business. The guidance concerns review of earned…
PLR 1103038: Agency receives extra time to correct private-activity-bond volume-cap elections
A state housing-finance agency asked for more time to amend separate Form 8328 elections for regular private-activity-bond volume cap and Housing Act volume cap. State administrative staff had…
PLR 1103026: Parent may claim a worthless-securities deduction for a subsidiary’s stock on liquidation
A parent company asked whether it could claim a worthless-securities deduction for the stock of a subsidiary that was winding up its business and would convert to a limited liability company. The…
PLR 1103025: Taxpayer may make a late election related to rehabilitation tax credits
A tax-exempt organization's wholly owned subsidiary, which served as a general partner in two partnerships developing a historic property, asked for more time to make an election under section…
IRS need not turn over a tax overpayment irrevocably elected as a future credit
Chief Counsel Advice considered whether the IRS had to turn over a tax overpayment to a Chapter 7 bankruptcy trustee after the taxpayer elected to apply the overpayment to a future tax liability.…
PLR 1103008: Section 162(m) does not limit compensation deductions for the subsidiary's employees on the stated facts
A foreign parent company's wholly owned United States subsidiary asked whether the section 162(m) deduction limit applied to compensation paid to its employees. The parent was a foreign private…
PLR 1103006: Five condominium units may be treated as one building for depreciation classification
A taxpayer developed one mixed-use building containing residential apartments, commercial space, parking, and community facilities, then proposed dividing the building into five condominium units.…
PLR 1102052: Trust settlement avoids transfer taxes and gain recognition
A family sought rulings on the federal tax effects of a mediated settlement involving two trusts created under a decedent’s will. The settlement resolved long-running disputes involving the rule…
PLR 1102051: IRS approves a settlement of disputed trust interests without additional tax recognition
A family settled a long-running dispute over how two trusts should distribute income and principal to descendants. The settlement used a negotiated fractional split between competing per capita and…
CCA 1102050: Nuclear-waste fee deductions do not create a specified liability loss
Chief Counsel advice considers whether a nuclear power company’s periodic payments under the Nuclear Waste Policy Act of 1982 can generate a specified liability loss under section 172(f). The advice…
PLR 1102024: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102023: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102022: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102021: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102020: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102019: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 1102018: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102017: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102016: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102015: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102014: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102013: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102012: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102011: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102010: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102009: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102008: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102007: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102006: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102005: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1102004: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 1101009: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101008: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101007: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101006: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101005: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101004: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101003: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101002: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1101001: IRS approves the federal tax treatment of a court-approved trust settlement
The personal representatives and beneficiaries of a deceased person's trusts asked how a proposed settlement would be treated for federal generation-skipping transfer, gift, estate, and income…
PLR 1052002: Court-approved trust settlement does not trigger the described tax consequences
A trust's beneficiaries were litigating how trust income and principal should be distributed under a will, a later agreement, and state law. They proposed a court-approved settlement that divided…
CCA 1052005: Changes to a § 48C project may affect its allocated credit
Chief Counsel Advice considers when changes to a project that was allocated a section 48C credit may be significant enough to affect the credit. It says the only change expressly allowed by Notice…
PLR 1051023: Trust settlement will not trigger GST, gift, estate, or income tax
The IRS considered a proposed settlement of litigation over two trusts created under a deceased person's will. The dispute concerned the rule against perpetuities, how trust principal and income…
CCA 1051021: Divorced parents may both claim a child as a dependent for § 139D benefits
Chief Counsel Advice addresses whether divorced, separated, or apart-living parents who are members of an Indian tribe may both treat their child as a dependent for purposes of IRC § 139D. The…
PLR 1051004: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051003: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 1051002: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
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.