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 1150015: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150014: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150013: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150012: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150011: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150010: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150009: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150008: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150007: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150006: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150005: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150004: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150003: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150002: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150001: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
Determination 1149054: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval covered eligible amortization charge bases established as of…
Determination 1149053: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149052: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149051: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149050: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
Determination 1149049: IRS approved a five-year extension for a multiemployer plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a multiemployer plan's unfunded liabilities. The approval applied to eligible amortization charge bases established as of…
PLR 1149048: IRS waived the 60-day IRA rollover deadline after a taxpayer's death
The IRS considered a request to waive the 60-day deadline for rolling IRA funds into another IRA. The deceased taxpayer had mental and medical conditions that affected his ability to manage his…
PLR 1149047: IRS waived the 60-day IRA rollover deadline after a bank error
The IRS considered a request to waive the 60-day deadline for rolling a distribution into an IRA. The taxpayer instructed a bank representative to complete a rollover, but the representative instead…
PLR 1149046: IRS waived the 60-day IRA rollover deadline after medical incapacity
The IRS considered a request to waive the 60-day deadline for rolling a distribution into an IRA. The taxpayer received the distribution after closing an IRA and intended to roll it into another…
IRS finalized denial of exemption for an organization testing green housing products
The IRS finalized its determination that an organization developing and beta-testing green residential products did not qualify for tax exemption under section 501(c)(3). The organization’s…
IRS denied exemption for a proposed supporting organization managing an LLC
The IRS finalized its determination that an organization formed to support a public charter school did not qualify for exemption under section 501(c)(3). The organization planned to manage an LLC…
IRS denied section 501(c)(4) exemption for a port management organization
The IRS finalized its determination that a nonprofit created by for-profit port operators did not qualify for exemption under section 501(c)(4). The organization provided management services,…
PLR 1149042: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149041: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149040: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149039: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149038: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149037: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149036: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
Determination 1149035: IRS revoked a charitable organization's exemption for operating commercial services
The IRS revoked a charitable organization's section 501(c)(3) exemption effective January 1, 20XX. It found that the organization's primary activities, including product ordering, shipping, and…
Determination 1149034: IRS revoked an organization's exemption for failing to substantiate its operations
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization failed to produce records and other information requested during an examination of its Form…
Determination 1149033: IRS revoked a charitable organization's exemption after asset diversion and record failures
The IRS revoked a charitable organization's section 501(c)(3) exemption effective January 1, 20XX. The organization had ceased operations and failed to provide records showing how its charitable…
PLR 1149032: IRS approved a local teachers' retirement fund dissolution and lump-sum distributions
The IRS ruled that a local teachers' retirement fund association could dissolve and distribute its remaining assets to members without losing its exemption under section 501(c)(11). The proposed…
Determination 1149031: IRS denied exemption to a fee-based financial planning organization
The IRS issued a final adverse determination after an organization failed to protest a proposed denial within 30 days. The organization offered financial education presentations and fee-based…
TEFRA proceeding determines partnership-level self-employment income
Chief Counsel Advice addressed what a TEFRA partnership proceeding should determine about self-employment income. It stated that the partnership level determines the allocation and gross amount of…
Refund claim period for a carryback linked to a partnership year
Chief Counsel Advice addressed when a partner may file a refund claim for a carryback year after resolution of the source partnership year. It stated that the partner may file within two years under…
Assessment period for unidentified indirect TEFRA partners
Chief Counsel Advice addressed whether the assessment period remained open for unidentified indirect partners after a timely TEFRA proceeding. It stated that, under section 6229(e), the statute…
Mitigation does not reopen an expired refund-claim year on these facts
Chief Counsel Advice addressed a potential refund claim for a closed taxable year. It stated that the statute of limitations had expired and that the mitigation provisions in IRC sections 1311…
Mitigation does not apply when no section 1312 circumstance exists
Chief Counsel Advice addressed whether mitigation could overcome the statute of limitations for an employer's refund claim. It agreed that none of the section 1312 circumstances of adjustment…
No-change partnership result can produce a partner-level adjustment
Chief Counsel Advice addressed the effect of a no-change result for partnership items at the partnership level. It stated that the result can still produce a computational adjustment at the partner…
Section 6103 does not authorize disclosure of tax records for a private-litigation subpoena
Chief Counsel Advice addressed a subpoena seeking agency tax records for use in private litigation. It stated that no provision of section 6103 authorizes disclosure of the records in response to…
Homeowners association section 528 election requires consent to revoke
Chief Counsel Advice addressed whether a homeowners association that elected section 528 treatment by filing Form 1120-H could revoke that election. It concluded that revocation is permissible only…
Amended Form 1065 is a nullity when an AAR is required
Chief Counsel Advice addressed an amended Form 1065 that sought to change the treatment of partnership items. It stated that the amended return was a nullity and that the partnership would need to…
Residual-value insurance contract is not insurance for federal tax purposes
The IRS concluded that a contract labeled as insurance against market decline was not a contract of insurance for federal income tax purposes. The contract protected against a lower-than-predicted…
Subsidiary treated as joining a consolidated return without Form 1122
The IRS ruled that a subsidiary was treated as having joined its parent’s consolidated federal income tax return even though Form 1122 was not filed with the return. The parent and subsidiary were…
IRS granted more time for a consolidated-loss carryback waiver election
The IRS granted an acquiring group an extension of time to file an election relinquishing the carryback period for consolidated net operating losses attributable to a target corporation. The…
IRS granted more time for a section 168 election
The IRS granted a subchapter S corporation an extension of time to make an election under section 168(h)(6)(F)(ii), which would allow it not to be treated as a tax-exempt entity for the alternative…
Bond rate-period change is not a significant modification
The IRS ruled that a taxpayer’s conversion of two build America bonds to a new term-rate period, with a new interest rate set under the bond terms, would not be a deemed exchange under section 1001.…
IRS granted more time for a section 198 remediation election
The IRS granted a taxpayer 60 days to make a section 198 election to deduct qualified environmental remediation expenditures for an earlier tax year. The taxpayer had relied on an accountant who did…
Worthless-stock deduction and intercompany gross-receipts look-through rules
The IRS ruled that a parent could claim a worthless-stock deduction for a subsidiary’s stock after the subsidiary dissolved, subject to the section 165(g) requirements and the consolidated-return…
Section 301.9100-3 cannot extend this statutory NOL election
The IRS denied taxpayers’ request for more time to make a section 172(b)(1)(H) net operating loss carryback election. It concluded that the election was statutory because its due date was set by the…
IRS granted inadvertent S-corporation termination relief
The IRS ruled that an S-corporation election terminated when the corporation’s stock was transferred to a partnership that was an ineligible shareholder. The transfer was not motivated by tax…
IRS approved a multi-business corporate separation and spin-off plan
The IRS approved a series of internal and external corporate reorganizations designed to separate three business segments within a large affiliated group. The plan included subsidiary liquidations…
Garage basis and optional garage fees excluded from housing-credit calculations
The IRS ruled that a low-income housing project could exclude the adjusted basis of separately leased garages from eligible basis under section 42(d)(1). The garages were not residential rental…
IRS granted late S-corporation election relief
The IRS granted relief for a corporation’s late election to be treated as an S corporation. The corporation intended the election to be effective on a specified date but did not timely file Form…
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.