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 1220011: IRS approves a two-stage corporate spin-off
The IRS ruled on a proposed separation of Business B from a publicly traded corporate group through an internal distribution followed by a pro rata spin-off to the parent company's shareholders. The…
PLR 1220010: Foreign subsidiary reorganization qualifies as a Type F reorganization
The IRS ruled that a proposed restructuring of a foreign subsidiary into a newly formed foreign holding company would qualify as a reorganization under IRC § 368(a)(1)(F). The restructuring included…
PLR 1220009: Foreign subsidiary share repurchase and restructuring qualify for specified tax treatment
The IRS considered a multinational corporate group's plan to repurchase publicly held stock of a foreign subsidiary, reorganize that subsidiary into a newly formed foreign company, and sell the…
PLR 1220008: Taxpayer receives more time to allocate GST tax exemption to a trust transfer
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The taxpayer's accountant had failed to file the…
PLR 1220007: Taxpayer receives more time to allocate GST tax exemption to a trust transfer
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The taxpayer's accountant had failed to file the…
PLR 1220006: Consent granted for a retroactive qualified electing fund election
The IRS allowed a limited partnership to make a retroactive qualified electing fund election for an investment in a foreign corporation that appeared to be a passive foreign investment company. The…
PLR 1220005: State educational instrumentality qualifies for deductible contributions
The IRS ruled that an organization created by a state legislature to support public schools serving students with vision and hearing impairments is an instrumentality of the state. The organization…
PLR 1220004: Unamortized debt issuance costs remain deductible separately from COD income
The IRS ruled that a taxpayer's unamortized debt issuance costs would remain deductible as a separate item when the taxpayer's debts were canceled or exchanged under a bankruptcy plan. The costs…
PLR 1220003: Consolidated group receives more time to elect an extended NOL carryback
The IRS granted a consolidated corporate group 60 additional days to elect an extended carryback period for a consolidated net operating loss. The group intended to make the election but did not…
PLR 1220002: Late S corporation election treated as timely
The IRS granted a newly formed corporation relief for failing to timely file its S corporation election. The corporation intended for the election to be effective on its formation date but did not…
PLR 1220001: Late S corporation election treated as timely
The IRS granted a newly formed corporation relief for failing to timely file its S corporation election. The corporation intended for the election to be effective on its formation date but did not…
IRS revokes a debt-management organization's tax exemption
The IRS issued a final adverse determination revoking a debt-management organization's exemption under IRC § 501(c)(3). The organization primarily solicited and enrolled consumers in debt-management…
PLR 1219039: IRS waives the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for an elderly taxpayer who intended to move IRA funds into a new IRA certificate of deposit but instead received a non-IRA certificate of deposit from…
PLR 1219038: IRS approves a conditional minimum funding waiver
The sponsor of a frozen pension plan asked the IRS to waive a minimum funding requirement after financial difficulties and poor plan investment returns. The IRS approved a conditional waiver for the…
PLR 1219037: IRS grants extra time to recharacterize a Roth IRA contribution
The taxpayer had a retirement plan containing traditional and Roth funds. When the plan was terminated, the plan administrator rolled both amounts into a traditional IRA, even though the Roth amount…
PLR 1219036: IRS waives rollover deadlines and grants recharacterization relief
The taxpayer asked the IRS to address several retirement-account errors made when financial-service personnel deposited funds into a Roth IRA instead of the intended traditional IRA. The IRS waived…
PLR 1219035: IRS grants extra time to recharacterize a Roth IRA
The taxpayer converted a traditional IRA to a Roth IRA after relying on an expected income level that was below the applicable conversion threshold. Revised partnership information later showed that…
PLR 1219034: IRS approves a private foundation's grant-making procedures
The IRS approved a private foundation's program to award grants to former fellows for projects improving civil legal services for poor, elderly, homeless, and disabled people and others deprived of…
PLR 1219033: IRS approves a private foundation scholarship program
The IRS approved a private foundation scholarship program for public high school students who have overcome significant obstacles and show exceptional promise or talent. The proposed program uses…
Determination 1219032: IRS denies section 501(c)(7) exemption to a craft guild
The IRS denied tax exemption to a nonprofit craft guild that held public craft shows and paid members the proceeds from their product sales. The organization argued that its shows, meetings,…
PLR 1219031: IRS approves a regulated electricity market counterparty structure
The IRS considered an independent system operator's plan to become the central counterparty for transactions in its regulated wholesale electricity markets. The operator would take title to the…
IRS denies section 501(c)(4) exemption to a facility rental organization
The IRS denied section 501(c)(4) exemption to a nonprofit that operated a large facility with office, conference, meeting, and lodging rentals. The organization rented to tax-exempt groups,…
IRS denies section 501(c)(3) exemption to a family trust
The IRS denied section 501(c)(3) exemption to a family trust established to pay health, education, welfare, and religion expenses for named relatives of the grantor. The trust agreement did not…
IRS denies section 501(c)(3) exemption to a grant conduit for a jewelry business
The IRS denied section 501(c)(3) exemption to a nonprofit formed to obtain grant funding for a for-profit jewelry business. The proposed nonprofit planned to send about 5 percent of any grant to…
IRS revokes a section 501(c)(3) organization's exemption for private spending
The IRS revoked a section 501(c)(3) organization's exemption after finding that its president used the organization's bank account for personal expenses and controlled its funds without adequate…
IRS revokes a student-housing organization's section 501(c)(3) exemption
The IRS revoked a student-housing organization's section 501(c)(3) exemption after concluding that its primary activity was operating and maintaining a chapter house for a university fraternity. The…
IRS denies exemption to a small synagogue and would classify it as a private foundation
The IRS denied section 501(c)(3) exemption to a small synagogue that operated in space provided by another congregation. The applicant had few documented activities, no board meeting minutes,…
PLR 1219024: IRS approves an international reorganization for an educational program
A public charity that teaches youth about work readiness, entrepreneurship, and financial literacy asked the IRS about a reorganization separating its U.S. and international operations. The charity…
CCA 1219023: IRS advice on designating a tax matters partner on an amended return
Chief Counsel Advice addresses whether a tax matters partner designation can be made on an amended partnership return. The advice says it cannot, because that would not comply with section…
CCA 1219022: IRS advice on whether a subsidiary affects the TEFRA small-partnership exception
Chief Counsel Advice considers whether a partnership can qualify for the small-partnership exception to the TEFRA rules when an S corporation owns a subsidiary. The advice says that if the S…
CCA 1219021: IRS advice on excluding accountable-plan meal reimbursements from a statistical sample
Chief Counsel Advice considers whether meals bought by employees and reimbursed under an accountable plan should be included in a target population and statistical sample used to test de minimis…
CCA 1219020: IRS advice on contracting for services involving tax information
Chief Counsel Advice addresses the procurement steps for hiring a court reporter for a live deposition when the contractor will receive tax information. The advice says the arrangement requires a…
CCA 1219019: IRS advice on a tax matters partner's authority to sign documents
Chief Counsel Advice addresses the designation of a tax matters partner and who may sign documents for a state law entity that is a TEFRA partnership. The advice says that designating a…
CCA 1219018: IRS advice on combining partnership proceedings for multiple years
Chief Counsel Advice addresses whether a single final partnership administrative adjustment can cover more than one tax year. The default rule is to issue a separate FPAA for each year because the…
CCA 1219017: IRS advice on identifying and signing for a tax matters partner
Chief Counsel Advice addresses how to identify the tax matters partner when neither partner is a manager. The advice says both partners are treated as member-managers under the regulation. If no…
CCA 1219016: IRS advice on who signs for an LLC serving as a tax matters partner
Chief Counsel Advice addresses signatures when an LLC serves as the tax matters partner of a TEFRA limited partnership. The advice says that an LLC manager under state law signs for the LLC. The tax…
PLR 1219015: Refined coal process may qualify for the section 45 credit
The IRS ruled for a taxpayer producing refined coal by mixing proprietary additives with feedstock coal before combustion. The process may produce refined coal for purposes of the section 45 credit…
PLR 1219014: Late S corporation election may be effective as of the intended date
The IRS granted relief to a small business corporation whose Form 2553, Election by a Small Business Corporation, was filed late. The corporation intended to be treated as an S corporation from a…
PLR 1219013: Service provider is not a third-party settlement organization
The IRS ruled that a company providing services through websites was not a third-party settlement organization with an information reporting obligation under section 6050W. The company accepted…
PLR 1219012: Trust income for a public entity's retiree benefits is excluded under IRC § 115(1)
A political subdivision asked whether income earned by a trust funding post-employment benefits for its eligible employees and dependents could be excluded from gross income. The IRS ruled that the…
PLR 1219011: Pooled reinsurance arrangement qualifies as insurance for federal tax purposes
A company asked whether its contracts with an affiliated insured qualified as insurance for federal income tax purposes. The company directly insured the affiliated corporation, ceded a substantial…
PLR 1219010: Pooled reinsurance for related insureds qualifies as insurance for federal tax purposes
A company asked whether its contracts with related insureds qualified as insurance for federal income tax purposes. The company directly insured a partnership and a corporation, ceded premiums and…
PLR 1219009: Pooled reinsurance for a medical partnership qualifies as insurance
A company asked whether its contracts with a medical partnership qualified as insurance for federal income tax purposes. The company directly insured the partnership, ceded premiums and risks to a…
PLR 1219008: Late S corporation election may be treated as timely
A corporation asked for relief because it did not timely file its election to be treated as an S corporation. The IRS concluded that the corporation had reasonable cause for the late filing and…
PLR 1219007: Extension granted to elect disregarded-entity status
An entity asked for more time to file an election to be treated as a disregarded entity for federal tax purposes. The IRS concluded that the entity met the requirements for relief under the…
PLR 1219006: Retiree health-benefit trust income is excluded under IRC § 115(1)
A retirement system asked whether income of its trust, which prefunded post-retirement hospital and medical benefits, was excludable from gross income. The IRS concluded that paying these benefits…
PLR 1219005: Permission granted to revoke a capital-gain investment-income election
Taxpayers asked to revoke an election that treated capital gain as investment income under IRC § 163(d)(4)(B)(iii). Their tax professional had mistakenly reported personal-loan interest as…
PLR 1219004: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect to defer U.S. income taxation on income accrued in three Canadian Registered Retirement Savings Plans under Revenue Procedure 2002-23 and the U.S.-Canada…
PLR 1219003: S corporation shareholders receive a ruling on a divisive reorganization
Two related shareholders asked the IRS about the tax consequences of separating an S corporation’s business into two corporations. The proposed transaction would transfer half of the existing…
PLR 1219002: IRS grants a married couple more time for Canadian RRSP elections
The IRS granted a married couple 60 days to make elections under Revenue Procedure 2002-23 to defer U.S. income tax on income accruing in their Canadian Registered Retirement Savings Plans. The…
PLR 1219001: Cooperative may treat c-Check payments as per-unit retains for its section 199 deduction
An agricultural cooperative asked whether payments it made to members before the end of its annual pool qualified as per-unit retain allocations paid in money. The cooperative called these payments…
IRS determination 1218041: Child-care organization denied section 501(c)(3) exemption
The IRS denied an organization’s application for recognition as a section 501(c)(3) exempt organization, effective from its incorporation date. The organization operated a daycare and afterschool…
PLR 1218040: IRS declines to waive the 60-day rollover requirement for an IRA distribution
A 63-year-old taxpayer asked the IRS to waive the 60-day deadline for rolling part of a SEP-IRA distribution into another IRA. The taxpayer said physical and mental health problems interfered with…
IRS determination 1218039: Minimum-funding waiver denied for a multiemployer plan
The IRS denied a request to waive the minimum funding standard for a multiemployer pension plan. The plan’s trustees argued that at least two contributing employers experienced substantial business…
PLR 1218038: IRS approves substitute mortality tables for a pension plan
The IRS approved a request to use substitute male and female mortality tables for specified populations in a pension plan. The approval applies for up to 10 years beginning with the plan year that…
PLR 1218037: IRS grants more time to recharacterize two Roth IRA conversions
A married couple asked for more time to recharacterize Roth IRA conversions after their tax advisor discovered that their modified adjusted gross income exceeded the limit for the relevant year. The…
PLR 1218036: IRS denies a law firm's request to waive its minimum funding contribution
A law firm asked the IRS to waive the minimum funding contribution for its pension plan for a specified plan year. The IRS denied the request because the firm's financial situation did not meet the…
PLR 1218035: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218034: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
PLR 1218033: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2008. The approval applied to the plan's amortization charge bases identified in…
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.