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 1121036: IRS waived the 60-day rollover requirement after a financial institution error
A taxpayer received a distribution from an individual retirement account and instructed a financial institution to deposit it into another IRA. The institution instead deposited the funds into a…
PLR 1121035: IRS waived rollover deadlines after a spouse's death and mental incapacity
A surviving spouse acting for a deceased taxpayer's estate asked the IRS to waive the 60-day rollover deadlines for distributions from an IRA and a retirement plan. The deceased taxpayer had…
PLR 1121034: IRS waived the 60-day rollover requirement after an account titling error
A taxpayer received a distribution from an IRA and asked a financial institution to deposit it into a rollover IRA in the taxpayer's name. An employee instead opened the account in the spouse's name…
PLR 1121033: IRS waived the 60-day rollover requirement after a financial advisor's deposit error
A taxpayer received a distribution from an IRA and asked a financial advisor to place the funds into another qualified account. The advisor instead deposited the amount into a non-IRA account at the…
PLR 1120011: fixed annual increases did not qualify as substantially equal payments
Two life insurance companies planned to issue annuities whose payments could increase each year by a fixed percentage selected when the contract was issued. They asked whether those payments…
PLR 1119040: IRS waives 60-day rollover deadline after adviser misappropriation
The IRS granted a waiver of the 60-day IRA rollover requirement after an adviser misappropriated the distributed funds and falsely prepared account statements. The taxpayer had closed an IRA,…
PLR 1118026: IRS waived the 60-day IRA rollover deadline
A taxpayer withdrew money from an IRA intending to roll it into another IRA, but the receiving financial institution failed to deposit the funds within the 60-day period. The taxpayer represented…
PLR 1118025: IRS declined to waive the 60-day IRA rollover requirement
A taxpayer withdrew money from an IRA to help fund a home purchase for an elderly family member, intending to redeposit the money after a reverse mortgage was completed. Delays caused the redeposit…
PLR 1118024: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of March 1, 2010. The extension applies to eligible amortization charge bases established as…
PLR 1118023: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2010. The extension applies to eligible amortization charge bases…
IRS approves a five-year amortization extension for an underfunded pension plan
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The approval applied to eligible amortization charge bases established as of January…
IRS approves a five-year amortization extension for an underfunded pension plan
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The approval applied to eligible amortization charge bases identified in the…
PLR 1117047: IRS rules that proposed ESOP warrants will not create a disqualified person or nonallocation year
The IRS considered an S corporation with an employee stock ownership plan that proposed to sell warrants for additional company stock to spouses of certain plan participants. The IRS treated the…
PLR 1117046: IRS declines to waive the 60-day IRA rollover deadline
The IRS considered a taxpayer who withdrew funds from an IRA, kept part of the distribution as three checks in a safe-deposit box, and deposited those checks into a second IRA after the 60-day…
PLR 1117045: IRS waives the 60-day IRA rollover deadline after institutional and health-related errors
The IRS considered a taxpayer who intended to roll an IRA distribution into another IRA but whose financial institution deposited the funds into a nonqualified account instead. The taxpayer also…
PLR 1117044: IRS waives the 60-day IRA rollover deadline after a bank error
The IRS considered an 81-year-old taxpayer who intended to roll an IRA distribution into two IRA certificates of deposit. A bank representative instead deposited the two portions into regular,…
PLR 1117043: IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS considered a taxpayer who intended to transfer an IRA certificate of deposit into a new IRA but whose financial institution opened a non-IRA account instead. The taxpayer discovered the…
PLR 1117042: IRS waives the 60-day IRA rollover deadline for a transfer into a special needs trust
The IRS considered a disabled taxpayer whose IRA funds were transferred into a trust account after a court authorized a special needs trust. The financial institution could not establish an IRA in…
PLR 1117041: IRS waives the 60-day IRA rollover deadline after a bank deposits funds into a non-IRA account
The IRS considered a 73-year-old taxpayer who intended to move funds from one IRA into an IRA certificate of deposit at a bank. An employee instead deposited the distribution into a non-IRA account,…
PLR 1117040: IRS waives the 60-day rollover deadline for an excess IRA distribution caused by an adviser error
The IRS considered a taxpayer whose financial adviser mistakenly directed an IRA distribution larger than the required minimum distribution. The taxpayer tried to redeposit the excess after learning…
PLR 1117039: IRS waives the 60-day rollover deadline after a Ponzi scheme made the funds unrecoverable
The IRS considered a married couple who took distributions from two IRAs to move the funds into more conservative investments. After fees were withheld, they deposited the net amounts into an…
PLR 1117038: IRS waives the 60-day rollover deadline after a broker misappropriates IRA funds
The IRS considered a taxpayer who closed several IRAs and annuities to consolidate the funds into rollover accounts. The taxpayer gave the distribution checks to a financial adviser, who prepared…
PLR 1117013: Variable annuity certificate treatment for an investment account
The IRS ruled on the federal tax treatment of a proposed certificate linked to an investment account and designed to provide a future annual benefit if the account were depleted under specified…
PLR 1117012: Annuity certificate treatment for an investment account
The IRS ruled on a proposed certificate linked to an investment account that would provide an annual benefit if the account were depleted under specified conditions. It concluded that the group…
PLR 1116045: Five-year extension approved for amortizing an underfunded pension plan's liabilities
The IRS approved a request for a five-year automatic extension to amortize a pension plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases…
PLR 1116044: IRS waived the 60-day rollover deadline after an advisor misappropriated IRA distributions
The IRS considered a taxpayer's request to waive the 60-day rollover requirement after a financial advisor misappropriated distributions from three IRAs. The taxpayer had intended to consolidate the…
PLR 1116043: IRS waived rollover deadlines after fraud involving an IRA and annuity
The IRS considered a taxpayer's request to waive the 60-day rollover requirements for distributions from an IRA and an annuity. The taxpayer intended to roll both distributions into replacement…
PLR 1116042: IRS waived the 60-day IRA rollover deadline after an advisor's fraud
The IRS considered a taxpayer's request to waive the 60-day rollover requirement for distributions from three IRAs. The taxpayer intended to consolidate the accounts and deposit the distributions…
PLR 1116041: IRS waived the 60-day IRA rollover deadline after an advisor's fraud
The IRS considered a taxpayer's request to waive the 60-day rollover requirement for distributions from two IRAs. The taxpayer intended to consolidate the accounts and deposit the distributions into…
PLR 1116040: IRS waived the 60-day IRA rollover deadline after fraud and bank refusals
The IRS considered a taxpayer's request to waive the 60-day rollover requirement after the taxpayer recovered funds from an investment fraud. The recovered amount included both IRA and non-IRA…
Determination 1116039: IRS approved a five-year extension for unfunded plan liabilities
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 applied to eligible amortization charge bases…
Determination 1116038: IRS approved a five-year extension for unfunded plan liabilities
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 applied to eligible amortization charge bases identified…
Determination 1116037: IRS approved a five-year extension for unfunded plan liabilities
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 applied to eligible amortization charge bases identified…
Determination 1116036: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of April 1, 2010. The extension applied to eligible amortization charge bases identified…
Determination 1116035: IRS approved a five-year extension for unfunded plan liabilities
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 applied to eligible amortization charge bases identified…
Determination 1116034: IRS approved a five-year extension for unfunded plan liabilities
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 applied to eligible amortization charge bases…
PLR 1115029: IRS waived the 60-day IRA rollover deadline
The IRS considered a taxpayer who moved money from an IRA into a non-IRA account and did not complete the rollover within 60 days. The taxpayer intended to transfer the money to a new IRA, supplied…
PLR 1115028: IRS allowed a surviving spouse to roll over inherited IRA funds
The IRS considered a surviving spouse who received a deceased spouse’s IRA through a trust and then took a one-time distribution based on advice from a financial professional. The trust gave the…
IRS waives the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for an individual who withdrew money from an IRA intending to redeposit it into another rollover IRA. A financial institution mistakenly placed the…
IRS waives the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for an individual who withdrew money from an IRA to select a new retirement investment. A bank employee incorrectly told the individual that the…
IRS declines a 60-day rollover waiver after a beneficiary's death
The estate representative of an annuity beneficiary asked the IRS to waive the 60-day rollover deadline after the beneficiary died. The beneficiary had received a distribution from a section 403(b)…
IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established…
IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established…
IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established…
IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases identified…
IRS waives the 60-day IRA rollover requirement for an ill taxpayer
The IRS waived the 60-day rollover requirement for an elderly taxpayer who received an IRA distribution intending to move it to another IRA. A serious medical condition, hospitalization, inability…
IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases established…
IRS waives the 60-day IRA rollover requirement after a duplicate distribution
The IRS waived the 60-day rollover requirement for an individual who received a duplicate IRA distribution because a financial institution did not follow his instructions. The first distribution was…
PLR 1113048: IRS waives the 60-day IRA rollover requirement after an advisor's error
An individual intended to roll an IRA distribution into another IRA, but a financial advisor deposited the amount into a non-IRA account instead. The taxpayer did not use the amount for another…
PLR 1113047: IRS waives the 60-day rollover requirement for an erroneous IRA distribution
An IRA owner received an extra distribution because of an error by the financial institution that administered the IRA. The taxpayer kept the check uncashed, later deposited the amount into a…
PLR 1113046: IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applied to the eligible amortization charge bases…
PLR 1113045: IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applied to the eligible amortization charge bases…
PLR 1113044: IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of April 1, 2010. The extension was effective for the plan year beginning April 1,…
PLR 1113043: IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applied to the eligible amortization charge bases…
PLR 1113042: IRS approves a five-year pension funding extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applied to the eligible amortization charge bases…
IRS determination 1111019: substitute mortality tables approved for a pension plan
The IRS approved a pension plan's request to use substitute mortality tables for specified healthy and disabled male and female populations. The approval covers up to 10 years beginning with the…
IRS determination 1111018: five-year amortization extension approved for pension plan
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The extension applies to eligible amortization charge bases established on January 1,…
IRS determination 1111017: pension contributions may be returned without disqualifying the plan
The IRS determined that up to $175,546 in employer contributions made for a defined benefit plan year could be treated as disallowed contributions for purposes of returning them to the employer. The…
PLR 1111016: policy credits from demutualization do not trigger distributions from tax-qualified contracts
The IRS considered a mutual holding company's planned sale, demutualization, and liquidation. Policyholders with certain tax-qualified retirement contracts would receive policy credits instead of…
PLR 1211034: IRS permits a surviving spouse to roll over IRA proceeds
The IRS ruled that a surviving spouse who was the sole beneficiary of a deceased spouse's estate could transfer the proceeds of the deceased spouse's IRA directly into the survivor's own IRA. The…
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.