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 1129012: IRS restores S corporation status after an inadvertent ineligible-shareholder transfer
The IRS considered a corporation whose S corporation election ended when its stock was transferred to a state limited liability company that was not an eligible S corporation shareholder. The…
PLR 1129011: IRS restores S corporation status after an inadvertent ineligible-shareholder transfer
The IRS considered a corporation whose S corporation election ended when its stock was transferred to a state limited liability company that was not an eligible S corporation shareholder. The…
PLR 1129010: IRS restores S corporation status after an inadvertent ineligible-shareholder transfer
The IRS considered a corporation whose S corporation election ended when its stock was transferred to a state limited liability company that was not an eligible S corporation shareholder. The…
PLR 1129009: IRS restores S corporation status after an inadvertent ineligible-shareholder transfer
The IRS considered a corporation whose S corporation election ended when its stock was transferred to a state limited liability company that was not an eligible S corporation shareholder. The…
PLR 1129008: Split-off of a subsidiary qualifies for tax-deferred reorganization treatment
The IRS considered a holding corporation that planned to transfer a subsidiary to a newly formed controlled corporation and distribute the controlled corporation's stock to the holders of a separate…
PLR 1129007: Communication towers and related income qualify for specified REIT tests
A communications infrastructure company asked how its towers, rooftop sites, related intangibles, tenant services, and foreign-subsidiary inclusions would be treated if it elected REIT status. The…
PLR 1129006: Merger and split-off qualify for specified tax-deferred treatment
A privately owned corporation proposed a series of steps involving subsidiary conversions, a merger exchange, a transfer of assets, and a split-off of a controlled corporation to certain…
PLR 1129005: Merger and split-off qualify for specified tax-deferred treatment
A privately owned corporation proposed a series of steps involving subsidiary conversions, a merger exchange, a transfer of assets, and a split-off of a controlled corporation to certain…
PLR 1129004: IRS grants relief for a late S corporation election
A corporation intended to elect S corporation status for a specified tax year but did not file the election on time. The IRS determined that the corporation had reasonable cause for the late filing…
PLR 1129003: IRS grants relief for a late S corporation election
A corporation's sole shareholder intended for it to be treated as an S corporation, but the corporation did not timely file Form 2553. The IRS determined that the corporation had reasonable cause…
PLR 1129002: Subpart F income from a commodity-investing subsidiary qualifies for RIC income testing
A regulated investment company planned to form and wholly own a foreign subsidiary that would invest primarily in commodities futures and related derivative instruments. The fund expected the…
PLR 1129001: IRS restores S corporation status after a late ESBT election
An S corporation's shareholder transferred the corporation's shares to a trust, but the trust's election to be treated as an electing small business trust was not timely made. The IRS determined…
IRS determination 1128038: IRS revokes a credit counseling organization's tax exemption
The IRS issued a final adverse determination revoking an organization's federal income tax exemption under § 501(c)(3), effective January 1, 2000. The IRS concluded that the organization was not…
IRS determination 1128037: IRS revokes a foundation's tax exemption after finding private benefit
The IRS issued a final adverse determination revoking a foundation's exemption under IRC § 501(c)(3), effective November 1, 2000. The IRS concluded that the foundation did not operate exclusively…
PLR 1128036: IRS approves dividing an inherited IRA for two estate beneficiaries
The IRS ruled for an estate representative who sought to divide a deceased owner's IRA into two inherited IRAs for the owner's children. The IRS concluded that the proposed trustee-to-trustee…
IRS determination 1128035: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization operated a training program for people affiliated with a…
IRS determination 1128034: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization trained and recruited members of a political party for…
IRS approves a private foundation's healthcare set-aside
The IRS approved a private foundation's plan to treat amounts set aside over five tax years as qualifying distributions for a healthcare clinic relocation and expansion project. The foundation also…
IRS determination 1128032: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization trained members of a political party for political office, and…
IRS determination 1128031: IRS revokes exemption after lodging activity and filing failures
The IRS issued a final adverse determination revoking a religious organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization offered lodging and…
IRS determination 1128030: IRS denies exemption for a marine technology program benefiting private businesses
The IRS denied exemption under IRC § 501(c)(3) to an organization formed to manage and fund a solar-powered marine transportation demonstration program. The organization planned to contract with…
IRS determination 1128029: IRS revokes exemption for an organization whose only activity was gaming
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization was formed to support medical and therapeutic services, but its only…
IRS determination 1128028: IRS denies exemption for a healthcare consulting organization serving foreign facilities
The IRS denied exemption under IRC § 501(c)(3) to a nonprofit membership corporation created by an exempt hospital to provide healthcare management, advisory, and consulting services around the…
PLR 1128026: IRS approves a private foundation's scholarship grant procedure
The IRS approved a private foundation's proposed procedure for awarding need-based scholarships to students attending post-secondary school. The foundation planned to publicize the program through…
PLR 1128025: IRS approves a proposed S corporation split-off and reorganization
The IRS approved tax treatment for a proposed transaction in which an S corporation would form a controlled corporation, transfer a qualified subchapter S subsidiary to it, and distribute the…
CCA 1128024: IRS addresses points and bundled services under the indoor tanning excise tax
Chief Counsel Advice addressed whether reward points, bonus credits, and similar devices are subject to the 10 percent indoor tanning services excise tax under IRC § 5000B. The memorandum concludes…
PLR 1128023: IRS grants relief for an inadvertently ineffective and terminated S corporation election
The IRS granted relief to a corporation whose S corporation election was ineffective because two trusts filed incorrect Electing Small Business Trust elections and later faced a foreign-trust issue.…
PLR 1128022: IRS treats a fund's subpart F income as qualifying RIC income
The IRS ruled that subpart F income earned by a regulated investment company through its wholly owned foreign subsidiary would be qualifying income under IRC § 851(b)(2). The fund intended to invest…
PLR 1128021: IRS grants relief for a late QSST election that invalidated S status
The IRS granted relief to a corporation whose S corporation election was ineffective because a trust shareholder did not timely file a qualified subchapter S trust election. The IRS determined that…
PLR 1128020: VEBA retiree health coverage qualified for the health coverage tax credit
An employer and a union asked whether a VEBA-funded retiree health plan created after the employer's bankruptcy and asset sale could qualify as health insurance for the health coverage tax credit…
PLR 1128019: IRS grants relief for an inadvertently invalid S corporation election
The IRS considered a corporation's S corporation election that was invalid because one shareholder was another corporation. The corporation discovered the problem, transferred the stock to the…
PLR 1128018: Consolidating two pre-1985 trusts preserved GST exemption and tax basis
The IRS considered a proposal to combine two substantially identical irrevocable trusts created before September 26, 1985. The trusts would be consolidated without changing the beneficiaries' income…
PLR 1128017: IRS treats a guaranteed account benefit contract as an annuity
An insurance company asked how a proposed contract would be treated for federal tax purposes. The contract would charge a fee and provide a lifetime benefit if an investment account fell below a…
PLR 1128016: IRS extends time to allocate generation-skipping transfer tax exemption
An estate asked for more time to allocate the decedent's generation-skipping transfer tax exemption to transfers for grandchildren and to two trusts. The estate had timely filed its estate tax…
PLR 1128015: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128014: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128013: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128012: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128011: IRS approves a trust reformation and income-principal allocation method
Trustees and beneficiaries asked whether they could reform a pre-1985 trust to clarify investment authority and allow a bank trustee to adjust receipts between income and principal under state law.…
PLR 1128010: IRS approves bond treatment for a public utility facility
A political subdivision asked how to apply the private activity bond rules to bonds financing improvements to an electric generation facility operated with a nongovernmental electric cooperative.…
PLR 1128009: IRS grants more time for a rental real estate election
A married couple asked for more time to elect to treat all of their rental real estate interests as one rental real estate activity for passive activity purposes. They had qualified for the election…
PLR 1128008: IRS treats new preferred shares of regulated funds as equity
A group of closed-end regulated investment companies asked whether new preferred shares, backed by liquidity facilities, would be treated as equity for federal income tax purposes. The funds planned…
PLR 1128007: IRS permits a construction company to revoke its look-back method election
A parent corporation asked to revoke its subsidiary's election to use the Simplified Marginal Impact Method for calculating look-back interest on long-term construction contracts. The subsidiary…
PLR 1128006: IRS grants relief for a late S corporation election
A corporation asked for relief after it failed to timely file Form 2553 to elect S corporation status. The IRS found reasonable cause for the late election. It allowed the corporation to make the…
PLR 1128005: IRS approves refined coal treatment and emissions testing methods
A partnership asked whether coal treated with chemical additives would qualify as refined coal for the federal refined coal production credit. It also asked whether pilot-scale combustion testing…
PLR 1128004: IRS grants extra time to file a consolidated return election
A new affiliated group asked for more time to elect to file a consolidated federal income tax return after a reverse acquisition changed its group structure. The group had not timely filed the…
PLR 1128003: IRS approves revised nuclear decommissioning-fund ruling amounts
A taxpayer that owns and operates part of a nuclear power plant asked the IRS to approve revised annual amounts for funding the plant's nuclear decommissioning reserve. The request followed an…
PLR 1128002: IRS grants extra time to file a duplicate Form 3115
A partnership asked the IRS for more time to file a signed duplicate copy of Form 3115, which it had used to request an automatic change in accounting method for depreciation. The partnership…
PLR 1128001: IRS grants extra time for a consolidated NOL carryback election
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The election would allow the group to carry the loss back three, four,…
PLR 1127022: IRS waives the 60-day IRA rollover requirement
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from an IRA into another retirement account. The individual said that a spouse's serious medical condition,…
Determination 1127021: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127020: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127019: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127018: five-year extension for a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The liabilities are described under IRC § 431(b)(2)(B) and § 431(b)(4), with…
Determination 1127017: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on the date stated in the final determination. The organization failed to establish that it operated exclusively for…
Determination 1127016: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on the date stated in the final determination. The organization failed to establish that it continued to operate for…
Determination 1127015: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1 of the redacted year. The organization failed to establish that it operated exclusively for exempt purposes and…
IRS determination 1127014: IRS denies exemption to a housing and credit counseling organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that proposed housing counseling, foreclosure prevention counseling, and financial education. The organization planned to charge…
PLR 1127013: IRS approves a hospital system's separate PAC and voluntary payroll deductions
A tax-exempt health care system asked whether it could establish and operate political action committees through a separate organization without jeopardizing its IRC § 501(c)(3) status. It also…
PLR 1127012: IRS approves an employer-related scholarship program
A private foundation asked for advance approval of a scholarship program for children of employees of three related companies. The IRS approved the program under IRC § 4945(g)(1), based on objective…
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.