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 1223013: IRS allows a late S corporation election
The IRS allowed a corporation to make a late S corporation election effective on its intended date. The corporation had filed Form 1120S but had not timely filed Form 2553, and the IRS found…
PLR 1223012: IRS approves a tax-neutral trust division and modification
The IRS approved corrections to two scrivener's errors in an irrevocable trust and a pro rata division of the trust into two successor trusts for separate family lines. The IRS ruled that the…
PLR 1223011: IRS allows late homeowners association elections
The IRS granted a homeowners association 120 days to make late elections under IRC § 528 for two taxable years. The association's CPA firm had filed Forms 1120 instead of the required Forms 1120-H.…
PLR 1223010: IRS grants ten foreign entities more time to elect disregarded status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1223009: IRS grants ten foreign entities more time to elect partnership status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as partnerships for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1223008: IRS allows a late S corporation election
The IRS allowed a corporation to make a late S corporation election effective on its intended date. The corporation had not timely filed Form 2553, and the IRS found reasonable cause for the…
PLR 1223007: IRS preserves S corporation status after QSST and shareholder errors
The IRS ruled that a corporation's S election terminated when a trust became an ineligible shareholder after a missed QSST election, shares were issued late to other eligible shareholders, and stock…
PLR 1223006: IRS approves expansion of an existing 80/20 company's business
The IRS ruled that a foreign manufacturing and infrastructure company's planned expansion would not add a substantial new line of business under IRC § 871(l)(1)(A)(iii). The expansion involved…
PLR 1223005: IRS allows a late low-income housing credit election
The IRS granted a taxpayer 120 days to correct Forms 8609 and elect to begin the low-income housing credit period in the year after a building was placed in service. An accountant had inadvertently…
PLR 1223004: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
PLR 1223003: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
PLR 1223002: IRS approves refined coal credit production and testing methods
The IRS approved three requested positions concerning a refined-coal facility that used chemical additives to reduce nitrogen oxide and mercury emissions. It concluded that coal produced through the…
PLR 1223001: IRS allows a change to the tax-book-value method for interest apportionment
The IRS permitted a domestic corporation that filed a consolidated federal return to change to the tax-book-value method for valuing assets when apportioning interest expense. The change applies for…
CCA 1311026: CCA addresses a bank’s deposit-account superpriority claim
Chief Counsel advice considered a bank’s potential superpriority under IRC § 6323(b)(10) for loans secured by a deposit account. The advice stated that a bank may obtain and perfect a security…
IRS denies exemption to a grant-making organization that could not document charitable control
The IRS denied a foreign-grant-making organization's application for recognition under section 501(c)(3). The organization supported a foreign school but did not document its grant review, follow-up…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases and was…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of October 1, 2009. The extension applies to the eligible amortization charge bases identified…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of September 1, 2008. The extension applies to the amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The extension applies to the amortization charge bases identified…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of October 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension 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…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS approves a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applies to eligible amortization charge bases…
IRS waives the 60-day rollover requirement because of a spouse's serious medical condition
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer had received the distribution while seeking a safer and more diverse investment option,…
IRS waives the 60-day rollover requirement after financial institution errors
The IRS waived the 60-day deadline for a taxpayer to roll a distribution from a SEP IRA into another eligible retirement plan. The taxpayer intended to keep an investment in a retirement plan, but…
IRS recognizes an employee retirement plan as a church plan
The IRS ruled that employees of a tax-exempt organization associated with a church are church employees for the church-plan rules. It also ruled that the organization's retirement Plan X qualifies…
IRS declines to waive a 60-day rollover deadline after a taxpayer lost household items during a move
The IRS declined to waive the 60-day deadline for rolling a distribution from an employee plan into an IRA. The taxpayer said that he was preoccupied with recovering furniture and other household…
IRS revokes a business league's exemption after event-centered operations
The IRS revoked an organization's exemption under IRC § 501(c)(6), effective January 1 of a redacted year. The organization was created to facilitate a public motorcycle event, but the IRS found…
IRS revokes a social club's exemption after investment income exceeds 35 percent of receipts
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective January 1 of a redacted year. The examination found that the club's investment income consistently exceeded 35 percent of…
IRS revokes a property-holding organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization held title to a building and collected rent for another entity, but…
IRS revokes a charity's exemption after personal expenses and inadequate records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The examination found that the organization paid personal expenses on the president's…
IRS revokes a charity's exemption after it ceases operations and fails to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization did not provide information requested during an examination, appeared to…
IRS revokes an inactive charity's exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1 of a redacted year. An examination found that the organization had been inactive and had no operations or regular…
IRS denies exemption to a fee-based fishing and retreat camp
The IRS denied an organization's application for exemption under IRC § 501(c)(3). The organization operated a fishing camp and retreat center that charged fees for lodging, meals, fishing, outdoor…
IRS approves a union's in-house pharmacy benefit program
The IRS ruled that a labor organization could operate its pharmacy benefit program through a wholly owned disregarded limited liability company without creating an unrelated trade or business. The…
IRS approves exempt-purpose transfers within a retirement-community system
The IRS ruled that a tax-exempt retirement community could transfer or share assets, personnel, facilities, and services with its supporting organization without jeopardizing its exemption. The…
IRS approves a new continuing-care retirement community
The IRS ruled that an existing public charity would remain exempt under IRC § 501(c)(3) and remain publicly supported under § 509(a)(2) after changing its name, moving its planned location, and…
IRS approves shared services among retirement-community organizations
The IRS ruled that a supporting organization could share assets, personnel, facilities, and services with the retirement communities it supported without creating unrelated business income. The…
CCA finds a partnership tax assessment extension validly signed
Chief Counsel advised that an IRS Form 872-P extending the time to assess partnership-level tax was valid. The tax matters partner was a limited liability partnership, and a managing partner…
CCA explains when Appeals may address a future-year item in a closing agreement
Chief Counsel Advice addressed whether Appeals may enter a closing agreement covering a specific item in a future taxable year while that year is under examination. The advice explained that a…
CCA addresses partnership proceedings after insufficient income reporting
Chief Counsel Advice addressed the IRS response when a partnership did not report enough income. The IRS would issue an FPAA to increase the partnership's income and restore any basis adjustment…
CCA explains accounting methods for manufacturers' long-term contracts
Chief Counsel Advice addressed whether a manufacturer may use the completed contract method for its contracts. A contract to produce a unique item, or an item normally requiring more than 12 months…
CCA explains levy and withholding rules for an ESOP distribution
Chief Counsel Advice addressed an IRS levy against a taxpayer's interest in an employee stock ownership plan. Dividends distributed from the ESOP under IRC § 404(k) are not subject to withholding…
PLR 1222034: IRS allows a late S corporation election for reasonable cause
The IRS ruled that a corporation could make a late election to be treated as an S corporation because it established reasonable cause for missing the filing deadline. The corporation intended the…
PLR 1222033: IRS grants extensions to allocate GST exemption to a trust
The IRS granted a husband and wife 120-day extensions to allocate their available generation-skipping transfer tax exemptions to an irrevocable trust. Their accountant had prepared gift tax returns…
PLR 1222032: IRS lets an S corporation continue after inadvertent termination
The IRS ruled that a corporation's S corporation election terminated when a trust failed to make a timely qualified subchapter S trust election and later another trust failed to make a timely…
PLR 1222031: IRS approves a tax-free spinoff of a controlled corporation
The IRS ruled on a proposed transaction in which a parent corporation would distribute all of its stock in a controlled corporation to its shareholders in proportion to their ownership. The…
PLR 1222030: IRS grants more time to waive a consolidated NOL carryback
The IRS granted a parent corporation an extension to file an election waiving the entire carryback period for a consolidated net operating loss. The parent intended to make the election with its…
PLR 1222029: IRS rules that petroleum-water services produce qualifying income
The IRS ruled that a limited partnership's income from removing, transporting, storing, and disposing of petroleum-water mix from oil and natural gas operations is qualifying income under the…
PLR 1222028: IRS treats late REIT elections as timely made
The IRS granted two companies an extension of time to make elections under section 856(c) to be treated as real estate investment trusts for a specified tax year. The companies discovered that the…
PLR 1222027: IRS preserves S corporation status after an inadvertent shareholder problem
The IRS ruled that a corporation's S corporation election may have terminated because an ineligible S corporation shareholder owned some of its stock. The IRS found that any termination was…
PLR 1222026: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification from its…
PLR 1222025: IRS allows a late S corporation election
The IRS ruled that a corporation may make a late election to be treated as an S corporation effective from its formation date. The corporation's shareholders intended to make the election but failed…
PLR 1222024: IRS allows another late S corporation election
The IRS ruled that a corporation may be treated as an S corporation from a specified effective date even though it did not timely file the election. The corporation established reasonable cause for…
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.