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 201223001: 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 201311026: 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 201222034: 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 201222033: 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 201222032: 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 201222031: 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 201222030: 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 201222029: Petroleum-water transport and disposal income qualifies
The IRS ruled that a limited partnership's income from transporting, storing, and disposing of petroleum-water mix from oil and natural gas wells, including associated condensate sales, is…
PLR 201222028: 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 201222027: 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 201222026: 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 201222025: 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 201222024: 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…
PLR 201222023: IRS grants late entity-classification and S corporation relief
The IRS granted a limited liability company more time to elect to be treated as an association taxable as a corporation and also allowed a late S corporation election. The company had intended to be…
PLR 201222022: IRS grants more time to waive bonus depreciation
The IRS granted a limited partnership 60 days to make an election not to claim 50-percent additional first-year depreciation for specified classes of qualified property. The partnership had filed…
PLR 201222021: IRS grants more time to defer tax on Canadian retirement savings
The IRS granted a U.S. resident 60 days to make an election under Rev. Proc. 2002-23 for deferral of U.S. federal income tax on income accruing in a Canadian Registered Retirement Savings Plan. The…
PLR 201222020: IRS allows a 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 Form 2553. The corporation established reasonable cause for the…
PLR 201222019: IRS grants more time for two taxpayers to defer Canadian RRSP income
The IRS granted a married couple 60 days to make elections under Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in their Canadian Registered Retirement Savings Plans. The couple had…
PLR 201222018: IRS excludes a governmental benefits trust's income under section 115
The IRS ruled that a trust pooling contributions from governmental employers to provide employee health and welfare benefits has income excluded from gross income under section 115(1). The trust…
PLR 201222017: IRS rules on tax treatment of a complex section 351 combination
The IRS issued rulings on the federal tax treatment of a planned combination involving a limited liability company, a corporation, a newly formed subsidiary, and a merger subsidiary. The rulings…
PLR 201222016: IRS rules on another complex section 351 combination
The IRS issued rulings on the federal tax treatment of a planned combination involving a limited liability company, a corporation, a newly formed subsidiary, and a merger subsidiary. The rulings…
PLR 201222015: IRS rules on another complex section 351 combination
The IRS issued rulings on the federal tax treatment of a planned combination involving a limited liability company, a corporation, a newly formed subsidiary, and a merger subsidiary. The rulings…
PLR 201222014: IRS rules on another complex section 351 combination
The IRS issued rulings on the federal tax treatment of a planned combination involving a limited liability company, a corporation, a newly formed subsidiary, and a merger subsidiary. The rulings…
PLR 201222013: IRS grants more time to allocate GST exemption to three trusts
The IRS granted a taxpayer 120 more days to allocate generation-skipping transfer tax exemption to transfers made to three irrevocable trusts. The taxpayer's accounting firm prepared and filed the…
PLR 201222012: IRS grants more time to make a section 754 election
The IRS granted a limited liability company more time to make a section 754 election for the taxable year in which a partner died. The election had been omitted from the partnership return even…
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.