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 1211033: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day deadline for a taxpayer to roll over a distribution from an IRA after finding that the taxpayer's medical condition and treatment impaired the ability to complete the…
PLR 1211032: IRS waives the 60-day IRA rollover deadline
The IRS waived the 60-day deadline for a taxpayer to roll over an IRA distribution after finding that incomplete information, inexperience with financial matters, and the taxpayer's medical…
PLR 1211031: IRS waives the 60-day qualified-plan rollover deadline
The IRS waived the 60-day deadline for a taxpayer to roll over a distribution from a qualified retirement plan after the plan administrator misfiled the rollover papers. The taxpayer had intended a…
PLR 1211030: IRS waives the 60-day rollover deadline after an administrative error
The IRS waived the 60-day deadline for a taxpayer to roll over a retirement-plan distribution after an administrative error caused the amount to be deposited into a non-IRA account. The taxpayer had…
PLR 1110019: five-year extension approved for a plan's unfunded liability amortization
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applies to eligible amortization charge bases…
PLR 1110018: 60-day IRA rollover deadline waived after advisor error
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from an inherited IRA and intended to move it into another IRA. The taxpayer's financial advisor mistakenly…
PLR 1110017: five-year extension approved for a plan's unfunded liability amortization
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension applies to eligible amortization charge bases…
PLR 1110016: amortization extension denied because the plan lacked a funding improvement plan
The IRS denied a request for an automatic extension of the period for amortizing a plan's unfunded liabilities. The plan year at issue began October 1, 2009. The actuarial certification stated that…
PLR 1110015: five-year extension approved for a plan's unfunded liability amortization
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing as of January 1, 2010. The extension is effective for the plan year beginning January…
PLR 1110014: 60-day IRA rollover deadline waived after advisor error
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew funds from an IRA after fearing that the financial institution might fail. A representative of another bank incorrectly…
PLR 1108047: IRS waives the 60-day IRA rollover deadline after a bank error
An individual received a distribution from an IRA and intended to roll the amount into a new IRA within 60 days. A bank mistakenly deposited the funds into a non-IRA account, and the individual did…
PLR 1108046: IRS approves most requested tax treatments for transfers to Puerto Rico retirement plans
A parent company and its subsidiary planned to transfer the assets and liabilities of two U.S. retirement plans into substantially identical Puerto Rico plans and related trusts. The IRS ruled that…
PLR 1108045: IRS approves a five-year extension for amortizing an employee plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a defined benefit plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge…
PLR 1108044: IRS approves a five-year extension for amortizing an employee plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a defined benefit plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge…
PLR 1108043: IRS waives the 60-day IRA rollover deadline after a custodian error
An individual directed financial institutions to move IRA funds into another IRA, but the receiving institution placed the funds into a non-IRA savings account. The individual asserted that the…
PLR 1107032: IRS waives the 60-day IRA rollover deadline
A surviving spouse received a distribution from an inherited IRA and intended to roll it into an IRA in her own name. A financial institution's adviser failed to establish the new IRA and deposited…
PLR 1107031: IRS waives the 60-day IRA rollover deadline after bank error
A surviving spouse received a distribution from her deceased spouse's IRA and intended to roll it into an IRA for herself. The bank treated the distribution as the taxpayer's own IRA but deposited…
PLR 1107027: IRS approves a five-year pension funding extension
The IRS approved a 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 established…
PLR 1106026: IRS waives an IRA rollover deadline after a financial institution error
The IRS considered a taxpayer's request to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer said a financial institution's error caused the funds to be placed…
PLR 1106025: IRS waives an IRA rollover deadline after the taxpayer did not learn of the distribution
The IRS considered a taxpayer's request to waive the 60-day deadline for rolling over an IRA distribution. The taxpayer said she did not know that her IRA custodian had closed the account and…
PLR 1106024: IRS waives an IRA rollover deadline after the custodian used the wrong account form
The IRS considered a taxpayer's request to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer instructed a financial institution to establish a rollover IRA,…
PLR 1106023: 60-day rollover deadline waived after caregiving and medical hardship
The IRS waived the 60-day rollover deadline for a taxpayer who intended to roll over part of an IRA distribution. During the rollover period, the taxpayer was caring for her husband after surgery…
PLR 1106022: Five-year extension granted 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 approval applied to the eligible amortization charge bases…
PLR 1106021: Five-year extension granted 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 approval applied to the eligible amortization charge bases…
PLR 1105047: IRA rollover deadline waived after a failed rollover was discovered late
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer believed the rollover had been completed, but the receiving financial institution…
PLR 1105046: IRA rollover deadline waived after a medical condition impaired a timely rollover
The IRS waived the 60-day deadline for a taxpayer to roll portions of an IRA distribution into a Roth IRA and a traditional IRA. The taxpayer temporarily moved the distribution into a non-IRA money…
PLR 1105005: IRS approves tax treatment of a guaranteed withdrawal annuity certificate
A life insurance company planned to issue a certificate linked to selected assets in a managed account. The certificate would allow withdrawals and provide a guaranteed minimum lifetime benefit if…
PLR 1105004: IRS approves tax treatment of a guaranteed withdrawal annuity
A taxpayer planned to purchase a certificate tied to selected assets in a managed account. The certificate allowed withdrawals and promised a guaranteed minimum lifetime benefit if the selected…
IRS approves a five-year pension-plan amortization extension
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases and…
IRS modifies a pension-plan amortization extension after a funded-ratio shortfall
The IRS approved a modification to an existing ten-year extension for amortizing a pension plan’s unfunded liabilities for the plan year beginning April 1, 2005. The modification followed a…
IRS approves a five-year pension-plan amortization extension for a 2009 plan year
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of October 1, 2009. The extension applies to the eligible amortization charge bases…
IRS approves a five-year pension-plan amortization extension
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of October 1, 2009. The extension applies to the eligible amortization charge bases…
PLR 1104061: IRS approves non-IRA payment of investment-advisory wrap fees
The IRS considered a securities broker-dealer and investment adviser that offered wrap-fee investment-advisory accounts to traditional IRA and Roth IRA holders. The fees covered recurring advisory,…
PLR 1104060: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered a 75-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104059: IRS waives the 60-day IRA rollover deadline after financial institution error
The IRS considered a 55-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104058: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered an 82-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104057: IRS waives the 60-day IRA rollover deadline after an investment instruction error
The IRS considered a taxpayer who instructed a financial institution to move money from one IRA investment to another IRA account. The institution instead distributed the money into a non-IRA…
PLR 1104056: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered a 73-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104055: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered a 48-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104054: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered a 41-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
PLR 1104053: IRS waives the 60-day IRA rollover deadline after custodian error
The IRS considered a 38-year-old taxpayer who transferred money from an IRA to an investment fund after financial institutions failed to establish the receiving account as an IRA. The taxpayer had…
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 existing as of January 1, 2010. The extension applies to the eligible amortization…
PLR 1104051: IRS waives the 60-day deadline for an IRA rollover
The IRS granted a married taxpayer a waiver of the 60-day deadline for rolling a distribution from an IRA into another IRA. The taxpayer had told a financial institution that the money was for…
IRS determination 1103060: IRS approves a conditional minimum-funding waiver for a multiemployer plan
The IRS approved a conditional waiver of the minimum funding standard for a multiemployer pension plan for the plan year ending August 31, 2009. The waiver requires specified contributions for later…
IRS determination 1103059: IRS approves a five-year extension for amortizing a plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a pension plan's unfunded liabilities. The extension applies to eligible amortization charge bases established as of May 1,…
PLR 1103058: IRS waives the 60-day IRA rollover deadline after an advisor's error
The IRS waived the 60-day deadline for an individual retirement account rollover. The taxpayer had withdrawn an amount from an IRA and instructed a financial advisor to transfer it back before the…
PLR 1102069: IRS waives the 60-day rollover deadline after a financial institution error
An individual received a distribution from an IRA and instructed a financial institution to place the funds into another IRA. Because of the institution's error, the funds were instead deposited…
PLR 1102068: IRS waives the 60-day rollover deadline after an account was opened incorrectly
An individual received a distribution from an IRA and instructed a financial institution to place part of it into a new IRA. The institution instead deposited that portion into a non-IRA money…
PLR 1102067: IRS waives rollover deadlines after serious medical problems
An older taxpayer received distributions from two IRAs and intended to roll both amounts into new IRAs within 60 days. Shortly afterward, he was hospitalized after brain cancer surgery and continued…
IRS approves a five-year pension-plan amortization extension for a 2009 plan year
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of September 1, 2009. The extension applies to the eligible amortization charge…
IRS approves a five-year pension-plan amortization extension for a 2010 plan year
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of March 1, 2010. The extension applies to the eligible amortization charge bases…
IRS approves a five-year pension-plan amortization extension for a 2009 plan year
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of October 1, 2009. The extension applies to the eligible amortization charge bases…
IRS approves a five-year pension-plan amortization extension for a 2010 plan year
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities as of June 1, 2010. The extension applies to the eligible amortization charge bases…
IRS waives the 60-day IRA rollover deadline after a medical incapacity
The IRS granted a taxpayer a waiver of the 60-day deadline for rolling an IRA distribution into a rollover IRA. The taxpayer had been hospitalized for bleeding in the brain and represented that the…
IRS approved a conditional waiver of a pension plan's minimum funding standard
The IRS approved a waiver of the minimum funding standard for a pension plan for the plan year ending December 31, 2006. The approval was conditional on collateral, required contributions, proof of…
PLR 1051027: IRS declines to waive the WRERA 180-day airline payment rollover deadline
An airline employee received a payment after the airline's qualified retirement plan was terminated in bankruptcy and asked to transfer it to a Roth IRA under section 125 of WRERA. The employee…
PLR 1051025: IRS approves a make-up IRA payment without treating it as a modification
An individual under age 59½ received substantially equal periodic payments from an IRA under the exception in IRC § 72(t)(2)(A)(iv). The custodian missed one monthly payment after changing the…
PLR 1050045: IRS waives 60-day IRA rollover deadline
A taxpayer withdrew money from an IRA after a financial institution employee incorrectly said the rollover period was 90 days. The taxpayer missed the 60-day deadline but kept the distribution in a…
PLR 1050044: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
PLR 1050043: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
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.