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 1221009: IRS restores S corporation treatment after an inadvertent ESBT failure
The IRS ruled that a corporation's S corporation election terminated when a trust acquired its shares without a timely electing small business trust election. The IRS found that the termination was…
PLR 1221008: IRS grants relief for S corporation terminations and a deemed-dividend election
The IRS granted relief to an S corporation whose election terminated after three years of excessive passive investment income and may also have terminated because of disproportionate shareholder…
PLR 1221007: IRS grants relief for a late S corporation election
The IRS granted relief to a corporation that intended to elect S corporation status but did not file the election on time. The IRS found that the corporation had reasonable cause for the late filing…
PLR 1221006: IRS restores S corporation treatment after an ineligible shareholder event
The IRS ruled that an S corporation election terminated when one of the corporation's partners became an ineligible shareholder by electing C corporation treatment. After the event was discovered,…
PLR 1221005: IRS grants more time to elect corporate tax classification
The IRS granted a limited liability company 120 additional days to file Form 8832 and elect to be treated as a corporation for federal tax purposes. The company had intended to be classified as a…
PLR 1221004: IRS includes two payments in the amount realized on a home sale
The IRS ruled that a married couple's amount realized on the sale of their former principal residence included both the payment received from the purchaser and a separate payment received from a…
PLR 1221003: IRS grants extra time to elect IC-DISC status
The IRS granted a taxpayer 60 additional days to file Form 4876-A and make an election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The taxpayer had been…
PLR 1221002: IRS gives mixed rulings on utility pilot-program equipment
The IRS issued mixed rulings on equipment installed by utility subsidiaries in customer pilot programs. It concluded that the equipment used in the pilots was seven-year property for depreciation,…
PLR 1221001: IRS allows a late accounting-method change after unusual hardship
The IRS granted a taxpayer permission to file a late Form 3115 and request an accounting-method change for an earlier tax year. The taxpayer had missed the election connected to temporary…
PLR 1220063: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of July 1, 2009,…
PLR 1220062: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of October 1, 2009,…
PLR 1220061: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of June 1, 2009,…
PLR 1220060: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases identified in the application and…
PLR 1220059: IRS approves a five-year extension for a plan’s unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases identified in the application and…
PLR 1220058: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of June 1,…
PLR 1220057: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of May 1, 2008, and…
PLR 1220056: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of June 1, 2009, and…
PLR 1220055: IRS waives the 60-day rollover deadline for two retirement-plan distributions
The IRS waived the 60-day rollover requirement for two distributions from a retirement plan. The taxpayer said that caring for a seriously ill child while serving on active military duty prevented a…
PLR 1220054: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220053: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2009,…
PLR 1220052: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220051: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to amortization charge bases established as of January 1, 2008,…
PLR 1220050: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2009, and applies to the…
PLR 1220049: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning June 1, 2009, and applies to eligible…
PLR 1220048: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning July 1, 2009, and applies to eligible…
PLR 1220047: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning March 1, 2010, and applies to eligible…
PLR 1220046: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning September 1, 2009, and applies to…
PLR 1220045: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning August 1, 2009, and applies to eligible…
PLR 1220044: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning November 1, 2009, and applies to…
PLR 1220043: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2008, and applies to…
PLR 1220042: IRS approves an automatic extension for a plan's unfunded liabilities
The IRS approved a plan's request for an automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2008, and applies to amortization…
PLR 1220041: IRS denies an automatic amortization extension
The IRS denied a plan's request for an automatic extension to amortize unfunded liabilities. The requested extension would have applied to the plan year beginning April 1, 2009. The IRS found that…
PLR 1220040: IRS approves a five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension is effective for the plan year beginning January 1, 2008, and applies to…
PLR 1220039: IRS denies a waiver of the minimum funding standard
The IRS denied a multiemployer plan's request to waive the minimum funding standard for the plan year ending May 31, 2005. The IRS concluded that the plan did not show that at least 10 percent of…
PLR 1220038: IRS approves a foundation's employer-related scholarship program
The IRS approved a private foundation's amended employer-related scholarship program under IRC § 4945(g)(1). The program would offer scholarships to certain employees' family members and, if funds…
PLR 1220037: IRS grants additional periods to dispose of excess business holdings
The IRS approved a charitable supporting organization's request for additional five-year periods to dispose of excess business holdings in a closely held company. The organization had increased its…
PLR 1220036: IRS approves a foundation's educational travel grant programs
The IRS approved a private foundation's grant-making programs that fund educational travel for disadvantaged children and young adults. One program supports travel within participants' own country,…
Final adverse determination: IRS denies Section 501(c)(6) exemption to a referral organization
The IRS denied a referral and networking organization's application for exemption under IRC § 501(c)(6). The organization promoted members' businesses through referrals, a searchable directory,…
Refund lookback limits apply to late-filed claims
Chief Counsel's advice explains how the refund limitations in IRC § 6511 apply when a taxpayer files an income tax return late. A late-filed return may satisfy the three-year claim period under §…
Disaster-area relief workers may qualify for interest abatement
Chief Counsel's advice addresses whether a disaster-area relief worker qualifies as an affected taxpayer under IRC § 7508A. A relief worker affiliated with a recognized government or philanthropic…
Retroactive PBGC payments may support an HCTC credit
Chief Counsel's advice considers whether a retroactive payment from the Pension Benefit Guaranty Corporation can count toward the health coverage tax credit for a particular month. The advice states…
PLR 1220030: IRS approves a trust construction without gift or GST tax consequences
The IRS approved a proposed judicial construction of a multigenerational trust involving marital, family, child, and grandchild trusts. The construction clarified how trust assets would be divided…
AMT is included in the accuracy-penalty underpayment
Chief Counsel's advice concludes that alternative minimum tax is included when calculating the “underpayment” used to determine an accuracy-related penalty. The memorandum interprets IRC § 6664 and…
Lessee must capitalize costs for improvements owned by lessor
Chief Counsel's advice considers a lessee that used its own funds, together with an allowance from the lessor, to construct improvements on leased real property. The agreement gave the lessor…
Ruling requests about purported Social Security trusts refused
Chief Counsel's advice addresses two nearly identical requests about purported trusts allegedly created when the Social Security Administration issued social security cards. The requesters claimed…
CAPCO tax credits create income when used to pay note obligations
Chief Counsel's advice considers a state-certified capital company whose investors received premium tax credits and used them to offset principal and interest owed on notes issued by the company.…
PLR 1220025: Consolidated group receives more time to waive NOL carryback
The IRS granted a consolidated group an extension of time to file an election relinquishing the entire carryback period for a consolidated net operating loss. The parent intended to make the…
PLR 1220024: S corporation keeps its election after stock and distribution errors
The IRS granted relief to a corporation whose S election may have been terminated after it issued additional stock and made non-pro rata distributions. The corporation represented that it intended…
PLR 1220023: Late S-election filing accepted for reasonable cause
The IRS granted a corporation relief after it failed to timely file Form 2553 to elect S-corporation status. The corporation's shareholder intended the election to be effective when the corporation…
PLR 1220022: RIC may pay special dividends in cash or stock
The IRS approved a regulated investment company’s proposed special dividends, which shareholders could elect to receive in cash or equivalent-value common stock. At least 20 percent of each…
PLR 1220021: Refined coal process qualifies for section 45 treatment
The IRS approved a refined-coal production process that mixes proprietary additives with feedstock coal before combustion. The ruling concludes that the process can produce refined coal for purposes…
PLR 1220020: Qualified stock purchase receives section 338(h)(10) treatment
The IRS ruled on a multinational group’s purchase of all the stock of a U.S. target from its parent and a related separation of another business. The stock purchase qualifies as a qualified stock…
PLR 1220019: Consolidated group receives more time for extended NOL carryback
The IRS granted a consolidated group 60 days to file an election extending the carryback period for a consolidated net operating loss. The parent missed the deadline after relying on a qualified tax…
PLR 1220018: Subsidiaries treated as joining a consolidated return despite missing Forms 1122
The IRS ruled that two subsidiaries were treated as having joined their parent's initial consolidated federal income tax return even though Forms 1122 were not timely filed. The subsidiaries' income…
PLR 1220017: Estate receives more time to file a QDOT citizenship notice
The IRS granted a qualified domestic trust more time to file Form 706-QDT and notify the IRS that the surviving spouse had become a United States citizen. The spouse had continuously resided in the…
PLR 1220016: IRS approves tax treatment for a multi-step corporate separation
The IRS ruled on a proposed separation involving three distributions and several contributions among a parent corporation, subsidiaries, and newly formed controlled corporations. The ruling treats…
PLR 1220015: IRS approves a spin-off and related corporate reorganization
The IRS approved a proposed separation of two business lines from a closely held S corporation through a spin-off, an acquisition, and a liquidation. The ruling treats the contribution and…
PLR 1220014: Taxpayer receives more time to elect RRSP income deferral
The IRS granted a U.S. citizen more time to elect deferral of U.S. income tax on earnings in a Canadian registered retirement savings plan. The taxpayer had relied on tax preparers who did not…
PLR 1220013: Taxpayer may revoke an election to forgo bonus depreciation
The IRS granted a corporation permission to revoke its election not to claim 50-percent additional first-year depreciation for eligible property. The corporation had also elected the related credit…
PLR 1220012: Related parties may complete linked like-kind exchanges
The IRS ruled that a taxpayer could receive like-kind replacement property from related parties through a linked series of deferred exchanges without losing the benefits of IRC § 1031. The related…
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.