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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 201222011: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222010: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222009: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222008: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222007: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222006: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 201222005: IRS approves a pooled fund's building reacquisition and related tax treatment
The IRS ruled on a tax-exempt organization’s plan to reacquire certain building interests from a pooled income fund in partial satisfaction of the fund’s debt. The IRS concluded that the…
PLR 201222004: IRS treats conservation easement credits as sale proceeds
The IRS concluded that granting a perpetual conservation easement in exchange for mitigation credits is a sale or exchange of property for federal income tax purposes. The taxpayer owned undeveloped…
PLR 201222003: IRS restores S corporation status after inadvertent termination
The IRS determined that a corporation’s S corporation election terminated after it had accumulated earnings and profits and more than 25 percent of its gross receipts were passive investment income…
PLR 201222002: IRS permits a corporation to use tax book value for interest apportionment
The IRS permitted a domestic corporation filing a consolidated federal return to change from the fair market value method to the tax book value method for valuing assets when apportioning interest…
CCA 201222001: entity changes did not make a parent and former subsidiary the same taxpayer for interest netting
Chief Counsel Advice concluded that a parent corporation and a former subsidiary were not the same taxpayer for purposes of interest netting under section 6621(d). The entities had gone through a…
PLR 201221057: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 201221056: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 201221055: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 201221054: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 201221052: IRS approves a five-year extension for amortizing plan liabilities
The IRS approved a request for a five-year automatic extension to amortize specified unfunded liabilities of a pension plan. The extension covers liabilities described under sections 431(b)(2)(B)…
PLR 201221051: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221048: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221047: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221046: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221045: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221044: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The approval covered liabilities described under IRC § 431(b)(2)(B) and § 431(b)(4), and…
PLR 201221039: IRS modifies funded-ratio conditions for a plan's amortization extension
The IRS approved a plan's request to modify conditions attached to an earlier approval of a 10-year extension for amortizing unfunded liabilities. The earlier approval required the plan to maintain…
PLR 201221037: IRS waives the 60-day rollover deadline after a financial institution's error
The IRS waived the 60-day deadline for rolling a distribution back into an IRA. A financial institution mistakenly distributed money from one IRA instead of another account, and the taxpayer did not…
PLR 201221036: IRS waives the 60-day rollover deadline after a medical emergency
The IRS waived the 60-day deadline for rolling an IRA distribution back into the taxpayer's IRA. The taxpayer had placed the distribution in another account, then underwent surgery for an extensive…
PLR 201221035: IRS waives the 60-day rollover deadline after incorrect tax advice
The IRS waived the 60-day deadline for a taxpayer to roll an IRA annuity distribution into a rollover IRA or IRA annuity. The taxpayer relied on an accountant's advice that surrendering the annuity…
PLR 201221031: IRS approves foundation payments for investment, accounting, and tax services
The IRS ruled that a private non-operating foundation may pay a related management company for investment, accounting, and tax services without those payments being acts of self-dealing under IRC §…
PLR 201221030: IRS approves a VEBA's expansion to state government employees
The IRS ruled that a voluntary employees' beneficiary association could expand its eligible membership from public-school employees to employees of any governmental unit in the same state without…
Determination 201221029: IRS revokes political training group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its training program primarily served a political party and its candidates. The organization trained…
Determination 201221028: IRS revokes women's political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 201221027: IRS revokes political leadership training group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 201221026: IRS revokes political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 201221025: IRS revokes women's political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
PLR 201221024: IRS approves museum, assistance, vending, and trademark rulings
The IRS ruled that a tax-exempt foundation operating a sports history museum could run a financial-assistance program for eligible members of an affiliated coaching association without jeopardizing…
Determination 201221023: IRS denies exemption to carbon-offset certification organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to certify service-company projects as carbon neutral and resell carbon offsets purchased from a for-profit company.…
Determination 201221022: IRS denies exemption to a small religious organization
The IRS denied a small religious organization's application for exemption under IRC § 501(c)(3). The organization described worldwide ministry, food-bank services, GED scholarships, and worship…
CCA 201221021: Chief Counsel says section 453A liability is subject to deficiency procedures
Chief Counsel Advice addressed whether the IRS should issue a statutory notice of deficiency to assess and collect a liability under IRC § 453A. The advice distinguished ordinary interest on…
CCA 201221020: Chief Counsel explains a section 6662A penalty calculation rule
Chief Counsel Advice addressed a question about the accuracy-related penalty under IRC § 6662A. It quoted § 6662A(b)(1), which says that certain reductions in excess deductions over gross income and…
CCA 201221019: Chief Counsel addresses TEFRA treatment of a one-partner entity
Chief Counsel Advice addressed whether the TEFRA partnership rules applied to a redacted entity. The advice said TEFRA applied for one year because the entity had a flow-through entity as a partner.…
CCA 201221018: Chief Counsel addresses reporting interest on unclaimed funds
Chief Counsel Advice addressed how a state office should report interest paid on unclaimed funds under IRC § 6049. The advice said that, assuming a reporting obligation exists, the interest should…
CCA 201221017: Chief Counsel addresses a partner’s bad-debt deduction
Chief Counsel Advice addressed when the worthlessness of a debt from a partner to a partnership should be determined. The advice said the issue would be decided in the partnership proceeding, not in…
CCA 201221016: Chief Counsel addresses TEFRA extensions of the assessment period
Chief Counsel Advice addressed how IRC §§ 6229 and 6501 interact in a TEFRA case. The advice said § 6229 extends a partner's § 6501 assessment period, citing decisions from three circuit courts and…
CCA 201221015: Chief Counsel says a disregarded entity is not a partnership partner
Chief Counsel Advice addressed whether a partnership existed for federal tax purposes. The advice concluded that a redacted entity was disregarded as separate from its owner and therefore was not…
CCA 201221014: Chief Counsel addresses the assessment period for restitution
Chief Counsel Advice addressed the period for assessing restitution. It stated that IRC § 6501(c)(11) allows an assessment of the restitution amount described in § 6201(a)(4) at any time. The advice…
CCA 201221013: Chief Counsel says extrapolation under Revenue Procedure 2011-43 is elective
Chief Counsel Advice addressed whether extrapolation was required when using the safe-harbor method in Rev. Proc. 2011-43. The advice agreed that extrapolation was not required to use the safe…
PLR 201221012: IRS grants more time for a rental real estate election
The IRS granted married taxpayers 120 additional days to make an election under IRC § 469(c)(7)(A) to treat all of their interests in rental real estate as one rental real estate activity. The…
PLR 201221011: IRS approves a revised nuclear decommissioning-fund schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's share of the costs of decommissioning a nuclear power plant under IRC § 468A. The taxpayer had used an independent…
PLR 201221010: IRS treats an S corporation election as continuing after an inadvertent ESBT filing 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 201221009: 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 201221008: 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 201221007: 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 201221006: 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 201221005: 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 201221004: 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 201221003: 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 201221002: 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 201221001: 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 201220063: 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 201220062: 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 201220061: 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,…
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.