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 201220060: 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 201220059: 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 201220058: 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 201220057: 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 201220056: 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 201220055: 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 201220054: 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 201220053: 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 201220052: 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 201220051: 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 201220050: 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 201220049: 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 201220048: 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 201220047: 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 201220046: 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 201220045: 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 201220044: 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 201220043: 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 201220042: 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 201220041: 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 201220040: 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 201220039: 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 201220038: 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 201220037: 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 201220036: 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 201220030: 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 201220025: 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 201220024: 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 201220023: 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 201220022: 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 201220021: 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 201220020: 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 201220019: 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 201220018: 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 201220017: 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 201220016: 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 201220015: 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 201220014: 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 201220013: 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 201220012: 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…
PLR 201220011: 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 201220010: 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 201220009: 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 201220008: 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 201220007: 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 201220006: 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 201220005: 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 201220004: 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 201220003: 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 201220002: 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 201220001: 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…
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.