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 1136035: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2010. The extension applied to the eligible amortization charge bases identified…
PLR 1136034: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136033: IRS approves a conditional minimum-funding waiver
The IRS approved a conditional waiver of a plan's required minimum funding contribution for a plan year ending September 30, 2009. The waiver required timely quarterly contributions, later…
PLR 1136032: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of June 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136031: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of April 1, 2010. The extension applied to eligible amortization charge bases established as…
PLR 1136030: IRS approves a five-year pension-plan amortization extension
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2011. The extension applied to eligible amortization charge bases established…
PLR 1136029: IRS waives the 60-day IRA rollover deadline
An IRA owner received a distribution check and relied on a financial advisor to roll the amount into another IRA. The advisor instead deposited it into a non-IRA account, and the taxpayer did not…
PLR 1136028: IRS approves a private foundation scholarship program
The IRS approved a private foundation's proposed scholarship program for graduates of designated high schools who live in specified locations and attend or plan to attend qualifying colleges or…
PLR 1136027: IRS approves an agricultural organization’s asset transfer upon dissolution
The IRS approved an agricultural organization’s plan to dissolve and distribute all or substantially all of its assets to another organization recognized as exempt under section 501(c)(5). The…
PLR 1136026: IRS approves a private foundation scholarship program
The IRS approved a private foundation’s scholarship procedures for students who attend or want to attend a specified university and demonstrate financial need. The scholarship program uses a…
PLR 1136025: IRS treats an omitted subsidiary as joining a consolidated return
The IRS ruled that a subsidiary could be treated as having joined its parent’s consolidated federal income tax return even though the subsidiary was omitted from the initial return and did not file…
CCA 1136024: An NOL carryback waiver also waives extended loss carrybacks
This Chief Counsel Advice concludes that a taxpayer who elects under IRC section 172(b)(3) to waive the net operating loss carryback period cannot carry back any portion of that year’s NOL,…
CCA 1136023: IRS explains low-income housing credit recapture after a later basis adjustment
This Chief Counsel Advice addresses recapture of the low-income housing credit when the IRS reduces a building’s eligible basis during an audit of a later, open tax year. It concludes that recapture…
CCA 1136022: A construction financing commitment fee is included in production expenditures
This Chief Counsel Advice concludes that a commitment fee paid for construction financing creates an asset whose adjusted basis must be included in accumulated production expenditures under Treas.…
CCA 1136021: A protective claim cannot extend the deadline for changing a foreign-tax election
This Chief Counsel Advice concludes that a taxpayer’s refund claim tied to cascading net operating loss and foreign tax credit carrybacks was untimely under the applicable limitation periods. It…
CCA 1136020: A surviving LLC should use Form 872, not Form 977, to extend assessment time
This Chief Counsel Advice concludes that a surviving LLC formed through a merger should use Form 872 to extend the assessment period for the merged entities’ tax liabilities. The surviving LLC is…
PLR 1136019: IRS grants more time to elect out of additional first-year depreciation
The IRS granted a taxpayer 60 days to make an election not to claim additional first-year depreciation for all classes of qualified property placed in service during a specified tax year. The…
PLR 1136018: IRS approves a wind farm’s treatment as property used in a U.S. possession
The IRS ruled that a wind farm would not be treated as property used predominantly outside the United States under the alternative depreciation system rules. The taxpayer represented that the wind…
PLR 1136017: Trust distributions under testamentary powers of appointment retain GST-tax exemption
The taxpayer asked whether exercising testamentary powers of appointment over three trusts would cause the appointed property to be included in the beneficiary's gross estate. The IRS ruled that it…
PLR 1136016: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136015: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136014: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136013: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136012: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136011: Proposed remainder-interest sales do not disturb GST exemption
The taxpayer proposed selling remainder interests in an old trust to separate trusts established for the sellers' descendants. The IRS ruled that a court construction allowing the sales, and the…
PLR 1136010: Foreign entity granted more time to elect partnership classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the election on time, and the IRS…
PLR 1136009: Proposed internal and external spin-offs qualify for tax-free treatment
A corporate group proposed separating two business segments through an internal spin-off followed by a distribution of the controlled corporation's stock to the parent corporation's shareholders.…
PLR 1136008: Public employer retiree-benefit trust receives favorable tax treatment
A city and a public authority proposed creating a trust to fund post-employment life insurance for retired employees and their beneficiaries. The IRS ruled that the trust's income would be excluded…
PLR 1136007: Public employer retiree-benefit trust receives favorable tax treatment
A public authority and a city proposed creating a trust to fund post-employment life insurance for retired employees and their beneficiaries. The IRS ruled that the trust's income would be excluded…
PLR 1136006: Taxpayer granted more time to file LIFO elections
A parent corporation asked for more time to file Forms 970 for fourteen subsidiaries that had used the LIFO inventory method but had not timely attached the required election forms. The IRS…
PLR 1136005: Taxpayers granted more time to elect qualified dividend income treatment
A married couple asked for more time to elect to treat qualified dividend income as investment income for purposes of the investment-interest deduction rules. Their tax preparer had failed to advise…
PLR 1136004: Inadvertent S corporation election remains effective
A limited liability company elected to be taxed as a corporation and then elected S corporation status, but its operating agreement gave members different rights to distributions and liquidation…
PLR 1136003: Nuclear decommissioning fund deduction and ruling schedules approved
A holding company that owned an interest in a nuclear power plant asked the IRS for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear…
PLR 1136002: Foreign entities granted time to elect partnership classification
Five foreign entities intended to be treated as partnerships for federal tax purposes but failed to timely file Forms 8832. The IRS found that the entities were eligible to make the elections, acted…
PLR 1136001: Foreign entities granted time to elect disregarded-entity status
Three foreign entities intended to be treated as disregarded entities for federal tax purposes but failed to timely file Forms 8832. The IRS found that the entities were eligible to make the…
IRS revokes foundation's tax-exempt status under section 501(c)(3)
The IRS Appeals Office issued a final adverse determination revoking a foundation's exemption under IRC § 501(c)(3), effective January 1, 2007. The IRS concluded that the foundation's primary…
PLR 1135035: IRS waives the 60-day IRA rollover period
Two taxpayers received IRA distributions and intended to roll the amounts into new IRAs within 60 days. A debilitating bacterial infection affected one taxpayer near the end of the rollover period,…
PLR 1135034: IRS waives the 60-day rollover period after account-classification errors
A taxpayer inherited an annuity that was incorrectly classified as a regular investment instead of an IRA. After a financial advisor recommended liquidating the annuity, the proceeds were deposited…
PLR 1135033: IRS approves a private foundation's medical scholarship program
A private foundation asked the IRS to approve procedures for scholarships to students pursuing medicine at an accredited college of medicine. The program uses stated eligibility criteria, a…
IRS revokes exemption for Main Street economic-development organization
The IRS issued a final adverse determination after an organization did not protest a proposed adverse determination within 30 days. The organization operated a Main Street program focused on…
PLR 1135031: IRS grants late QSub election relief after S status termination
The parent corporation asked the IRS to allow a subsidiary to make a QSub election even though the election date preceded the five-year waiting period that ordinarily follows termination of the…
CCA 1135030: Unamortized hedge gain must be recognized when debt is repurchased
Chief Counsel Advice addressed whether a taxpayer could defer the unamortized gain from an interest-rate hedge when it elected to defer cancellation-of-debt income under IRC § 108(i). The hedge was…
CCA 1135029: IRS requests more facts before deciding accounting-method issues
Chief Counsel Advice addressed the accounting method of an S corporation that provided health-related consulting services and had expanded into supplying equipment. The questions concerned whether…
PLR 1135028: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135027: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135026: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135025: IRS approves tax treatment for a complex corporate split-off
A corporate parent requested rulings on the federal income tax consequences of a proposed and partially completed series of transactions designed to separate one business from an affiliated group…
PLR 1135024: IRS grants late GST exemption allocations after tax-preparer error
A married couple asked the IRS for more time to allocate their generation-skipping transfer tax exemptions to transfers they had made to an irrevocable trust. They intended to make the allocations…
PLR 1135023: IRS allows a late S corporation election after a missed Form 2553 deadline
The company asked the IRS to recognize its S corporation election effective on the date it was incorporated, even though it did not timely file Form 2553. The company said its shareholders intended…
PLR 1135022: IRS revokes a prior de minimis fringe benefit ruling without retroactive effect
The IRS revoked an earlier private letter ruling that had treated certain clothing and accessories provided by an employer to employees as de minimis fringe benefits excluded from gross income.…
PLR 1135021: IRS grants more time for a partnership to make a late § 754 election
The limited liability company asked for more time to make a § 754 election after a transaction caused a termination under § 708(b)(1)(B). The election would allow adjustments to the basis of…
PLR 1135020: IRS grants extra time for a foreign entity to elect partnership classification
The foreign entity asked the IRS for more time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the classification to apply from an earlier…
PLR 1135019: IRS grants late S corporation election relief
The corporation asked the IRS to recognize its S corporation election effective on a specified date, even though it did not timely file Form 2553. The corporation's sole shareholder intended for it…
PLR 1135018: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135017: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135016: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135015: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135014: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135013: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135012: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for some consenting…
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.