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 1225003: IRS grants relief for an ineffective and terminated S election
An S corporation asked for relief because its S election was made effective before the corporation was incorporated and later would have terminated when trust shareholders failed to make QSST…
PLR 1225002: IRS grants more time for a Canadian RRSP election
A U.S. resident asked for more time to make an election under Rev. Proc. 2002-23 for a Canadian registered retirement savings plan. The taxpayer had established the plan before becoming a U.S.…
PLR 1225001: IRS grants late entity-classification and S-election relief
An LLC asked for more time to elect corporate tax classification and for relief to make a late S corporation election. The IRS concluded that the taxpayer satisfied the reasonable-cause and…
PLR 1224047: IRS waives the 60-day IRA rollover deadline
An IRA owner asked the IRS to waive the 60-day rollover deadline after a financial institution mistakenly transferred funds from an IRA to a non-IRA account. The taxpayer also experienced a medical…
PLR 1224046: IRS waives the 60-day rollover deadline for a plan-loan offset
A retirement plan participant asked the IRS to waive the 60-day rollover deadline after a plan loan was treated as in default and offset against the participant's account. The participant relied on…
PLR 1224045: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224044: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224043: IRS waives the 60-day rollover deadline for part of a retirement-plan distribution
An older taxpayer received a retirement-plan distribution that was mistakenly deposited into a nonqualified brokerage account instead of an IRA. A representative of the financial company…
PLR 1224042: IRS recognizes three employee benefit plans as church plans
A nonprofit organization affiliated with a religious society asked whether three employee benefit plans qualified as church plans under IRC § 414(e). The organization was controlled by a committee…
PLR 1224041: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224040: IRS grants a five-year extension to amortize a multiemployer plan's unfunded liabilities
The IRS approved a five-year automatic extension for a multiemployer plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of…
PLR 1224039: IRS approves a private foundation's scientific research grant program
The IRS approved a private foundation's proposed grants to individuals conducting scientific research into consciousness and related subjects. The foundation planned to select researchers based on…
PLR 1224038: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship program for people employed in the produce industry and their immediate relatives. The foundation planned to select students based on…
IRS denies VEBA status to an insurance trust
The IRS denied an insurance trust's request for recognition as a voluntary employees' beneficiary association under IRC § 501(c)(9). The trust made insurance coverage available to employees of…
IRS denies exemption to a cannabis dispensary
The IRS denied a nonprofit corporation's application for exemption under IRC § 501(c)(3). The organization distributed cannabis to members who had medical referrals, and it also provided related…
IRS denies exemption to four-unit condominium association
The IRS denied a mutual benefit corporation's application for exemption under IRC § 501(c)(4). The organization maintained the exterior of four condominium units and related common areas, funded by…
IRS denies social-welfare exemption to founder-controlled advocacy group
The IRS denied a founder-controlled advocacy organization's application for exemption under IRC § 501(c)(4). The organization described programs involving environmental action, law-enforcement…
CCA discusses penalties and backup withholding in a worker-classification case
Chief Counsel Advice addresses how the government may protect its interests in a worker-classification case. The advice considers an employer that treated workers as independent contractors and an…
CCA addresses offsetting overpayments after an erroneous refund
Chief Counsel Advice considers whether the IRS may offset an overpayment of one excise tax against another tax liability when the liability was reported but never assessed before the assessment…
CCA addresses state privacy restrictions on IRS summonses
Chief Counsel Advice considers whether a Connecticut privacy statute would prevent IRS personnel from obtaining residential-address information about a taxpayer in a protected category. The advice…
CCA addresses electronic copies of gift tax returns
Chief Counsel Advice evaluates a proposed IRS system for scanning paper gift tax returns and attachments into a searchable electronic database. It explains when scanned copies may become the…
CCA finds a public utility eligible for the section 1341 exception
Chief Counsel Advice considers whether a taxpayer that sold a regulated product qualified as a regulated public utility for the public-utility exception to the inventory rule in IRC § 1341(b)(2).…
PLR 1224028: IRS allows late revocation of an investment-income election
The IRS granted an individual taxpayer 60 days to revoke an election that treated qualified dividends and net capital gains as investment income under IRC § 163(d)(4)(B). The taxpayer's former…
PLR 1224027: IRS allows late revocation of an investment-income election
The IRS granted an individual taxpayer 60 days to revoke an election that treated qualified dividends and net capital gains as investment income under IRC § 163(d)(4)(B). The taxpayer's former…
PLR 1224026: IRS grants late S corporation election relief
The IRS granted a corporation 120 days to submit a late Form 2553 election to be treated as an S corporation. The corporation intended the election to be effective on a specified date but did not…
PLR 1224025: IRS grants extra time to elect IC-DISC status
The IRS granted a corporation 60 days to file Form 4876-A and make a late election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The corporation formed…
PLR 1224024: IRS treats a late Form 1128 as timely filed
The IRS granted a C corporation relief for a late Form 1128 requesting a change in its annual accounting period. The taxpayer missed the filing deadline because of a clerical error, but represented…
PLR 1224023: IRS treats LNG sales income as qualifying income
The IRS ruled that a publicly traded partnership's income from selling liquefied natural gas, or LNG, would be qualifying income under IRC § 7704(d)(1)(E). The partnership planned to buy domestic…
PLR 1224022: IRS grants foreign entities more time to elect disregarded status
The IRS granted three foreign limited liability companies 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities missed the filing deadline…
PLR 1224021: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224020: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224019: IRS grants more time for a late special-use valuation election
The IRS granted an estate 120 days to make an election under IRC § 2032A to specially value qualified farmland and related structures. The executor did not include the election on the estate's…
PLR 1224018: IRS approves captive insurer's pooled reinsurance arrangement
The IRS ruled that a captive insurer's contracts with affiliated businesses, combined with participation in a reinsurance pool of unrelated insurers and insureds, constituted insurance for federal…
PLR 1224017: IRS grants more time to file an accounting-method change
The IRS granted an affiliated group 60 days to file the original and signed duplicate copies of Form 3115 for a change in the amortization method for certain assets. The group had filed its…
PLR 1224016: IRS grants more time to file a depreciation-method change
The IRS granted an affiliated group 60 days to file the original and signed duplicate copies of Form 3115 for a change in the depreciation method for certain assets. The group had filed its…
PLR 1224015: IRS allows a late Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to make a late election to defer U.S. federal income tax on income accruing in one Canadian Registered Retirement Savings Plan. An accounting firm had filed the…
PLR 1224014: IRS restores S corporation status after missed ESBT elections
The IRS ruled that a corporation's S election terminated when two trusts became shareholders without timely making the required Electing Small Business Trust elections. The IRS determined that the…
PLR 1224013: IRS preserves S corporation status after eight missed ESBT elections
The IRS ruled that a corporation could continue to be treated as an S corporation after the trustees of eight shareholder trusts failed to make timely Electing Small Business Trust elections. The…
PLR 1224012: IRS rules reorganized funds will not be publicly traded partnerships
The IRS ruled that, after a reorganization, each new investment fund that is classified as a partnership for federal tax purposes will not be treated as a publicly traded partnership. The funds will…
PLR 1224011: IRS rules reorganized funds will not be publicly traded partnerships
The IRS ruled that, after a reorganization, each new investment fund that is classified as a partnership for federal tax purposes will not be treated as a publicly traded partnership. The funds will…
PLR 1224010: IRS grants more time for a foreign disregarded-entity election
The IRS granted a domestic corporation 120 days to file Form 8832 for its wholly owned foreign subsidiary and elect to treat the subsidiary as a disregarded entity effective on its formation date.…
PLR 1224009: IRS grants more time for a foreign disregarded-entity election
The IRS granted foreign subsidiary Y 120 days to file Form 8832 and elect to be treated as a disregarded entity effective on its formation date. Y had missed the filing deadline, while its parent,…
PLR 1224008: IRS grants more time for a foreign partnership election
The IRS granted foreign company X 120 days to file Form 8832 and elect to be treated as a partnership effective on a specified earlier date. X had been classified by default as an association and…
PLR 1224007: IRS restores S corporation status after a missed ESBT election
The IRS ruled that a corporation's S corporation election terminated when shares were transferred to a trust whose trustee failed to make the required Electing Small Business Trust election. The IRS…
PLR 1224006: IRS approves a multi-step corporate reorganization
The IRS approved federal tax treatment for a multi-step corporate reorganization involving a conversion, a reincorporation, and contributions of interests in newly formed entities. The conversion…
PLR 1224005: IRS allows late filing of accounting-method forms
The IRS granted a taxpayer 30 days to attach the original Forms 3115 to the correct tax return for two accounting-method changes. The taxpayer had attached the forms to an earlier year's return even…
PLR 1224004: IRS allows a late S corporation election
The IRS granted a corporation relief for failing to timely file its S corporation election. The IRS found that the corporation had reasonable cause for the late filing and allowed the election to be…
PLR 1224003: IRS allows a late extended NOL carryback election
The IRS granted a consolidated group 60 days to make a late election under IRC § 172(b)(1)(H) to carry back a consolidated net operating loss for an extended period. The parent had intended to make…
PLR 1224002: IRS allows late filing of a duplicate Form 3115
The IRS granted a taxpayer 30 days to file a signed duplicate Form 3115 with the IRS Ogden office. The taxpayer had timely attached the original form to its return but mailed the required duplicate…
PLR 1224001: IRS approves refined-coal process and emissions testing
The IRS ruled that a process adding proprietary chemicals to feedstock coal before combustion produces refined coal under IRC § 45(c)(7), provided the coal comes from the same source or rank as the…
PLR 1223023: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day rollover requirement for a taxpayer who had taken a distribution from an individual retirement annuity and failed to complete the rollover because of a cognitive…
IRS approves a private foundation's grant-making program
The IRS approved a private foundation's procedures for a grant-making program intended to develop leadership and community-development skills. The program uses an open nomination process, objective…
IRS approves endowment units for a charitable remainder trust
The IRS ruled that a charitable remainder trust's contractual units in an organization's endowment would not generate unrelated business taxable income. The trust would have a contractual right to…
IRS denies exemption to a time-bank membership organization
The IRS issued a final adverse determination denying § 501(c)(3) exemption to a membership organization that operated a community time bank. Members exchanged services using units of time, and the…
CCA 1223019: IRS clarifies an excise-tax overpayment credit
Chief Counsel advice corrected an earlier analysis concerning whether an excise-tax overpayment could be credited against another excise-tax liability. The advice states that if the taxpayer paid…
CCA 1223018: IRS identifies the form for waiving a CDP hearing
Chief Counsel advice identifies Form 13207 as the form for waiving the right to receive a Collection Due Process hearing under IRC § 6330. The advice also points to the Internal Revenue Manual…
CCA 1223017: IRS explains review of a supplemental CDP determination
Chief Counsel advice states that the attorney handling a remanded Collection Due Process case should review the supplemental notice of determination before it is issued to the taxpayer. The review…
CCA 1223016: IRS may issue separate deficiency notices for different taxes
Chief Counsel advice states that IRC § 6212(c) does not prevent the IRS from issuing deficiency notices for different taxes reported on separate returns. After a notice concerning an individual's…
TAM 1223015: Trade promotion rebates accrue when customers buy goods
The IRS concluded that an accrual-method manufacturer's trade promotion rebate liabilities become fixed and determinable when customers purchase the goods. The later submission of claim forms and…
PLR 1223014: IRS approves utility normalization treatment for excess project costs
The IRS ruled that a public utility's treatment of project costs above a regulatory cost cap satisfied the normalization requirements for accelerated depreciation. The utility included the full…
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.