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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CCA 1050031: A net operating loss election could not be revoked without the related WHBAA election
Chief Counsel Advice considered whether a taxpayer could revoke an election under IRC § 172(b)(3) to waive the net operating loss carryback period. The advice explained that the election could be…
PLR 1050027: Grain payments treated as per-unit retain allocations paid in money
The IRS ruled for a farmers’ cooperative that made payments to members for grain marketed through the cooperative. It concluded that the payments were per-unit retain allocations paid in money under…
PLR 1050017: IRS classified a state-created association as a division, not a political subdivision
The IRS considered whether a state-created association administering a no-fault medical compensation plan was a political subdivision of the state. The IRS concluded that the association did not…
PLR 1050012: IRS ruled that the taxpayer's officers were not covered employees for a short taxable year
The IRS considered whether a corporation's officers were covered employees for a short taxable year that ended when the corporation became part of an affiliated group after a merger. The corporation…
PLR 1050008: IRS approved consolidating three trusts without triggering new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050006: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
PLR 1050005: IRS approved consolidating three related trusts without new tax consequences
The IRS considered a plan to consolidate three related trusts into one trust to reduce administrative costs. The trusts had substantially similar beneficiaries, trustees, and distribution terms, but…
CCA 1049040: Form 6251 lines 3 and 8 do not apply to trade or business taxes
Chief Counsel Advice agrees with a conclusion about Form 6251, which is used in calculating alternative minimum tax. The memorandum states that lines 3 and 8 do not apply to taxes incurred in…
CCA 1049038: Retirement means permanent withdrawal of depreciable property
Chief Counsel Advice addresses the meaning of “retirement” for depreciable property. It states that retirement means permanently withdrawing depreciable property from use in a trade or business or…
TAM 1049029: Bundled programming packages can qualify for the domestic production deduction
This Technical Advice Memorandum considers whether gross receipts from licensing a programming package can qualify as domestic production gross receipts under IRC § 199. The package included…
CCA 1049028: Expanded exclusion covers certain health-professional loan repayment and forgiveness amounts
This Chief Counsel Advice addresses the expanded exclusion under IRC § 108(f)(4) for certain payments under health-professional loan repayment and forgiveness programs. It concludes that the…
CCA 1049026: An adult home care house qualifies as residential rental property
This Chief Counsel Advice considers whether a house used for an adult home care business qualifies as residential rental property for depreciation purposes. The residents lived in the house…
PLR 1049018: Bond redemption will not by itself break the low-income housing credit financing test
This ruling addresses a low-income housing project financed in part with a loan funded by tax-exempt bonds. The project expected to meet the requirement that at least 50 percent of its basis,…
PLR 1049007: Cooperative grower payments qualify as per-unit retain allocations
This ruling addresses a farmers' cooperative that processes and markets members' and nonmembers' crops. The IRS concluded that the cooperative's cash grower payments, including initial, interim,…
PLR 1049003: University venue agreement does not trigger the private business use test
A university and a public authority asked whether a media company's rights under an agreement would create private business use of improvements financed with tax-exempt bonds. The agreement covered…
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.