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 1141007: Planned finance company qualifies as a cooperative corporation
A group of separately organized member firms planned to form a finance company that would provide treasury services, loans, and credit support to the firms and their affiliates. The proposed company…
PLR 1141006: Nuclear decommissioning deduction and ruling schedules approved
A taxpayer with a direct ownership interest in a nuclear power plant requested a schedule of deduction amounts for a special transfer to its nuclear decommissioning fund and a revised schedule of…
PLR 1141005: Nuclear decommissioning deduction and ruling schedules approved
A taxpayer with a direct ownership interest in a nuclear power plant requested a schedule of deduction amounts for a special transfer to its nuclear decommissioning fund and a revised schedule of…
PLR 1141004: IRS grants time for environmental remediation elections
A real estate leasing company incurred qualified environmental remediation expenditures in two years but did not make the section 198 elections needed to deduct them in those years. It later claimed…
PLR 1141003: IRS grants more time to elect IC-DISC status
A domestic corporation intended to elect interest charge domestic international sales corporation status for its first taxable year but did not timely file Form 4876-A. The corporation relied on its…
PLR 1141002: IRS grants more time for a section 754 election
A partnership missed the deadline to make a section 754 election after the death of a partner and the transfer of that partner's interest. The partnerships represented that they relied on a tax…
PLR 1141001: IRS grants more time for a section 754 election
A partnership missed the deadline to make a section 754 election after the death of a partner and the transfer of that partner's interest. The partnership represented that it relied on a tax…
IRS revokes exempt status of a down payment assistance organization
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exempt status effective January 1, 2007. The organization provided down payment assistance to home buyers,…
PLR 1140030: IRS grants time to file a qualified separate line of business election
A company asked for more time to file Form 5310-A and make a qualified separate line of business election for a testing year. The request arose after the company learned that a wholly owned…
PLR 1140029: Foundation's set-aside qualifies as a distribution
A private operating foundation asked whether it could treat a set-aside for energy-efficient window replacement and drainage improvements as a qualifying distribution. The projects involved…
PLR 1140028: Sale of a stadium does not end a charity's scholarship-based exemption
The IRS ruled that a nonprofit organization could sell a baseball stadium and stop operating it without losing its exemption under IRC § 501(c)(3). The organization would use the sale proceeds and…
PLR 1140027: IRS approves revised private-foundation scholarship procedures
The IRS approved a private foundation’s revised procedures for awarding scholarships to eligible high school, undergraduate, and graduate students. The foundation added a merit-based guideline for…
PLR 1140026: IRS approves a monitored scholarship program for a private foundation
The IRS approved a private foundation’s advance request to operate a scholarship program called Y. The program would cover tuition for undergraduate, graduate, or advanced study in the United States…
CCA 1140025: FPAA adjustments and consistent settlement agreements
Chief Counsel Advice addressed how adjustments in a partnership-level notice, called an FPAA, interact with settlements and requests for consistent agreements by partners who did not settle. The…
CCA 1140024: Partnership filing penalties are not partnership items
Chief Counsel Advice considered whether a penalty for a partnership’s failure to file would be a partnership item under the TEFRA partnership procedures. The advice concludes that the penalty is not…
CCA 1140023: An AAR does not alter an FPAA’s final partnership-item determination
Chief Counsel Advice explains how an administrative adjustment request, or AAR, affects a final partnership administrative adjustment, or FPAA. The advice states that the FPAA should use the…
PLR 1140022: IRS approves nuclear decommissioning fund deduction and ruling schedules
The IRS approved a taxpayer’s request for a schedule of deduction amounts and a revised schedule of ruling amounts for a nuclear decommissioning fund. The ruling permits a special transfer of a…
CCA 1140021: Fees tied to nontaxable communications services are not taxable
Chief Counsel Advice reconsidered an earlier conclusion about separately stated fees charged with communications services. It concludes that fees used only with nontaxable services, such as bundled…
PLR 1140020: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1140019: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1140018: Fund granted more time to make a mark-to-market election for PFIC stock
A domestic investment fund asked for extra time to make a mark-to-market election under IRC § 1296 for stock of a passive foreign investment company held indirectly through a foreign partnership.…
PLR 1140017: IRS approves a holding-company reorganization and related tax treatment
A publicly traded parent corporation proposed inserting a new holding company above it through a merger with a newly formed subsidiary. The parent shareholders would receive holding-company stock,…
PLR 1140016: Corporation granted more time to request a dual consolidated loss closing agreement
A successor corporation asked for extra time to request a closing agreement related to dual consolidated losses after a restructuring moved corporations from one consolidated group to another. The…
PLR 1140015: Taxpayer may switch to tax book value for interest-expense apportionment
A domestic corporation asked to change how it values assets when allocating and apportioning interest expense for federal income tax purposes. The corporation and its affiliated group had used the…
PLR 1140014: LLC receives relief for late entity-classification and S corporation elections
An LLC asked for relief after failing to timely file elections to be treated as a corporation and as an S corporation for federal tax purposes. The IRS granted the LLC 120 days to file Form 8832 and…
PLR 1140013: Tax-exempt controlled entity granted more time to make depreciation election
A for-profit corporation owned by an exempt organization asked for extra time to elect not to be treated as tax-exempt for purposes of the tax-exempt-use-property rules. The election affected the…
PLR 1140012: Fund's late RIC and spillover-dividend elections treated as timely
A regulated investment fund asked for relief after its administrator failed to timely mail an automatic filing extension application. Because the application was late, the fund's return did not…
PLR 1140011: Parent granted more time to elect an extended CNOL carryback
The common parent of a consolidated group asked for extra time to elect an extended carryback period for a consolidated net operating loss. The group missed the filing deadline for the election…
PLR 1140010: S corporation election reinstated after a missed ESBT election
A company asked whether its S corporation election could continue after stock was sold to a trust that qualified as an electing small business trust, but no ESBT election was properly filed. The IRS…
PLR 1140009: Foreign subsidiary conversion and stock exchange approved
A parent company asked how a planned restructuring would be treated for federal income tax purposes. The plan converted one foreign subsidiary into another legal form, then exchanged shares of a…
PLR 1140008: Intra-group sales and rescissions disregarded for federal tax purposes
A corporate group asked how several completed transfers among related companies should be treated after the group discovered that the transfers had moved assets outside the intended business…
PLR 1140007: Consolidated group granted more time to elect an extended NOL carryback
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The election was not timely filed because the group relied on a…
PLR 1140006: Trust income for public retiree health benefits excluded under IRC § 115
A city asked whether income earned by a trust that funds health insurance premiums for eligible retired public employees would be excluded from gross income. The IRS concluded that providing these…
PLR 1140005: Nuclear decommissioning deduction and ruling schedules approved
A nuclear plant owner asked for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The request relied on transitional…
PLR 1140004: Nuclear decommissioning deduction and ruling schedules approved
A nuclear plant owner asked for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The request relied on transitional…
PLR 1140003: REIT granted more time to make a consent dividend election
A real estate investment trust asked for more time to make a consent dividend election after its tax return included forms with the wrong entities identified as the shareholder and corporation. The…
PLR 1140002: Hydrogen pipeline qualifies for additional first-year depreciation
An industrial gas business asked whether a newly constructed hydrogen pipeline could qualify for the additional first-year depreciation deduction under IRC § 168(k). The IRS determined that the…
PLR 1140001: QDOT trustee granted more time to report beneficiary citizenship
A qualified domestic trust trustee asked for more time to notify the IRS and certify that the surviving spouse beneficiary had become a United States citizen. The notice was missed because the law…
Determination 1139013: IRS revoked a credit counseling organization's exemption after finding its main activity was selling debt-management plans
The IRS issued a final adverse determination revoking a credit counseling organization's exemption under IRC § 501(c)(3), effective January 1, 2001. The IRS found that the organization operated…
PLR 1139012: IRS waived the 60-day IRA rollover deadline after an advisor's error
An individual used money distributed from an IRA to buy company stock after a financial advisor incorrectly said the investment could be made outside the IRA trustee's custody. The individual…
PLR 1139011: IRS allowed a minor beneficiary to roll recovered retirement funds into an inherited IRA
The taxpayer was a minor who inherited a deceased parent's qualified retirement plan, but the guardian took a taxable lump-sum distribution instead of arranging a direct transfer to an inherited…
PLR 1139010: IRS approves an educational competition foundation's grant procedures
The IRS approved a private foundation's procedures for grants connected to an international student competition that develops critical thinking, teamwork, communication, and technology skills. The…
CCA 1139009: IRS treated the section 183 issue as a partnership item
Chief Counsel Advice concluded that applying IRC § 183 was a partnership item under Treas. Reg. § 301.6231(a)(3)-1(b). The advice viewed the result as favorable to the taxpayer because, without §…
CCA 1139008: IRS described the deadline for a refund after a Tax Court decision
Chief Counsel Advice stated that the IRS had two years from the date a Tax Court decision became final to issue a resulting refund. The advice explained that a decision becomes final 90 days after…
CCA 1139007: IRS advised against using IDRS for a non-tax-administration purpose
Chief Counsel Advice stated that the Integrated Data Retrieval System should not be used for a purpose that is not tax administration. It directed the recipient to IRC § 6103(h)(1) and invited…
CCA 1139006: IRS denied a section 199 deduction that would create an election-year NOL
Chief Counsel Advice considered the interaction of the domestic production deduction under IRC § 199, net operating losses under § 172, and the one-time dividends-received deduction election under §…
PLR 1139005: IRS approved a REIT's proposed hotel leasing and management structure
The IRS addressed a real estate investment trust's proposed restructuring of the ownership, leasing, and management of a hotel. The hotel would be leased to a taxable REIT subsidiary, while an…
PLR 1139004: IRS let a taxpayer revise its asset-disposition plans without invalidating an earlier ruling
The IRS issued a supplemental ruling concerning a previously approved transaction under IRC §§ 338 and 368. The taxpayer had originally represented that a corporation's acquired assets would not be…
PLR 1139003: IRS approved mortgage-interest subsidies for servicemembers and their reporting treatment
The IRS considered a mortgage servicer group's plan to subsidize interest for servicemembers covered by the Servicemembers' Civil Relief Act. The subsidy would reduce the servicemember's effective…
PLR 1139002: IRS approved nuclear decommissioning deduction and ruling-amount schedules
The IRS approved a nuclear power plant owner's request for a schedule of deduction amounts and a revised schedule of ruling amounts for its nuclear decommissioning fund. The ruling applied…
PLR 1139001: IRS treated an S election as continuing after an inadvertent stock-issuance error
An S corporation had an agreement to issue shares to a shareholder but mistakenly treated the shares as not outstanding while holding them in trust. The IRS ruled that, if this error terminated the…
Determination 1138054: IRS revoked a social club's exemption after persistent nonmember use of its facilities
The IRS revoked a social club's exemption under IRC § 501(c)(7). The club's nonmember receipts from facility use exceeded the 15 percent guideline for at least three years, and the club advertised…
Determination 1138053: IRS denied a pension plan's minimum funding waiver
The IRS denied a company's request to waive the minimum funding standard for its pension plan. Although the company was experiencing financial distress, the IRS concluded that the hardship was not…
PLR 1138052: IRS waived the 60-day rollover deadline after an advisor's error
An individual withdrew money from an IRA to invest in a hedge fund after a financial advisor incorrectly advised that the transaction would be a proper rollover. The individual did not learn that…
PLR 1138051: IRS waived the 60-day rollover deadline for two advisor-mishandled IRA transfers
Two spouses transferred amounts from their IRAs to accounts in a hedge fund after a financial advisor incorrectly advised that labeling the accounts as IRAs would make the transfers proper…
Determination 1138050: IRS denied exemption to a group supporting a foreign religious school
The IRS denied exemption under IRC § 501(c)(3) to a group that solicited donations in the United States and sent them to a foreign religious school. The group could not document pre-grant inquiries,…
PLR 1138049: IRS approved a private foundation's need-based scholarship procedures
The IRS approved a private foundation's scholarship program for students pursuing a bachelor's degree or higher who cannot afford the cost of school. The program uses published eligibility rules,…
CCA 1138048: Employee must include guests' flight costs in income even if the employee does not fly
Chief Counsel Advice addressed whether an employee must include the flight costs of guests in income when the employee does not take the flight. The advice stated that each passenger's flight must…
CCA 1138047: Domestic production receipts and income are partnership items
Chief Counsel Advice addressed how the domestic production deduction rules apply to a partnership. It stated that domestic production activity gross receipts and the resulting gross income are…
CCA 1138046: SUV excluded from passenger-automobile depreciation limits based on weight rating
Chief Counsel Advice considered whether a taxpayer's SUV was subject to the depreciation limits for passenger automobiles. The advice concluded that the SUV was not a passenger automobile under IRC…
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.