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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Determination 1035039: Five-year amortization extension approved
The IRS approved a five-year automatic extension for amortizing a plan's unfunded liabilities as of May 1, 2009. The extension applied to eligible amortization charge bases identified in the…
PLR 1035037: 60-day rollover waiver granted after bank error
The IRS waived the 60-day rollover requirement after a financial institution mistakenly deposited part of a retirement-plan distribution into a non-IRA account. The taxpayer had intended to move the…
PLR 1035036: Rollover waiver granted for employer stock
The IRS waived the 60-day rollover requirement for a taxpayer who received 9,385 shares of employer stock after a qualified domestic relations order awarded her an interest in a former spouse's…
PLR 1034025: IRS declined to waive the 60-day IRA rollover requirement
The IRS considered a taxpayer who received a distribution from an IRA and deposited it into a high-interest checking account instead of a qualified IRA. The taxpayer later invested the money in…
PLR 1033041: IRS waives the 60-day rollover deadline after bereavement and financial-institution error
The IRS considered a surviving spouse’s request to roll several IRA and retirement-plan distributions into a rollover IRA after the 60-day deadline had expired. The taxpayer attributed the delay for…
PLR 1033040: IRS waives a rollover deadline after a financial-institution error
The IRS considered a taxpayer’s request to roll part of an IRA distribution into another IRA after the 60-day deadline had expired. The taxpayer stated that a financial-institution employee…
PLR 1031043: IRS approved a governmental excess benefit arrangement for contributions exceeding section 415 limits
The IRS approved a governmental excess benefit arrangement for a hospital district's governmental pension plan. The arrangement would hold employer contributions that could not be made to the…
PLR 1031042: IRS approved rollover treatment for a final pension payment after funding improves
The IRS ruled that the final payment of a participant's elected pension lump sum could qualify as an eligible rollover distribution if the plan became sufficiently funded within the represented…
PLR 1031041: IRS waived the 60-day rollover deadline after an investment manager misdirected an IRA distribution
The IRS waived the 60-day rollover requirement for a taxpayer whose IRA distribution was mistakenly deposited into a joint non-IRA brokerage account. The taxpayer had instructed an investment…
PLR 1031040: IRS waived the 60-day rollover deadline after an adviser failed to establish an IRA
The IRS waived the 60-day rollover requirement for a taxpayer whose retirement-plan distribution was deposited into a non-IRA account after a financial adviser failed to establish the requested IRA.…
PLR 1031039: IRS waived the 60-day rollover deadline after misleading financial advice
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew funds from two IRA annuities and deposited the proceeds into a taxable account. The taxpayer said a financial adviser…
PLR 1031038: IRS waived the 60-day rollover deadline after a financial institution opened a nonqualified account
The IRS waived the 60-day rollover requirement for a 78-year-old taxpayer whose IRA distribution was deposited into a nonqualified taxable account. The taxpayer intended to move the funds into…
PLR 1030038: IRS ruled a divorce transfer did not modify IRA payments
The IRS ruled on a taxpayer's transfer of part of an IRA to a former spouse under a divorce agreement. It concluded that the transfer was nontaxable under IRC § 408(d)(6). It also concluded that…
Determination 1030037: IRS approved a five-year extension for pension-plan amortization
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of April 1,…
Determination 1030036: IRS approved a five-year extension for pension-plan amortization
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The extension applied to eligible amortization charge bases established as of April 1,…
PLR 1029029: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of June 1, 2009. The extension applied to eligible amortization charge bases established as…
PLR 1029028: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2009. The extension applied to eligible amortization charge bases established as…
PLR 1029027: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of July 1, 2009. The extension applied to eligible amortization charge bases identified in…
PLR 1029026: IRS approves a conditional minimum-funding waiver for a community hospital
The IRS approved a waiver of a plan's minimum funding standard for the plan year ending December 31, 2009. The waiver was conditional on timely quarterly contributions, later contributions…
PLR 1029025: IRS declines to waive the 60-day rollover requirement
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from a qualified plan into an IRA. He said that he lost track of the rollover while handling several retirement…
PLR 1029024: IRS waives the 60-day rollover requirement after a financial institution error
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from one IRA into another IRA. The funds were placed in a taxable, non-IRA account because a financial institution…
PLR 1029023: IRS waives two 60-day IRA rollover requirements after custodian delays
Two taxpayers asked the IRS to waive the 60-day deadline for rolling investment interests from their IRAs into successor IRAs. Their original custodian resigned and did not timely provide assignment…
PLR 1029022: IRS waives the 60-day rollover requirement after a bank error
A surviving spouse asked the IRS to waive the 60-day deadline for rolling her deceased husband's flexible annuity IRA into a rollover IRA. She endorsed and mailed the distribution check to her…
PLR 1029021: IRS declines to waive the 60-day rollover requirement after an online application error
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from one IRA into a new IRA. He intended to complete a trustee-to-trustee transfer online, but the application…
PLR 1029020: IRS waives the 60-day rollover requirement after a fund-registration error
An individual asked the IRS to waive the 60-day deadline for rolling an IRA distribution into an IRA investment. A fund was not registered as a qualified IRA investment with the original…
PLR 1029019: IRS waives the 60-day rollover requirement because of a medical condition
An individual asked the IRS to waive the 60-day deadline for rolling a distribution from a traditional IRA into another IRA. He liquidated a certificate of deposit, placed the funds in a non-IRA…
PLR 1028047: The IRS waived the 60-day rollover deadline because of a medical condition
The IRS waived the 60-day rollover requirement for a taxpayer who had withdrawn funds from an IRA but did not complete the rollover on time because a medical condition impaired her ability to handle…
PLR 1028046: The IRS waived the 60-day rollover deadline after erroneous financial advice
The IRS waived the 60-day rollover requirement for a taxpayer who delayed rolling an IRA distribution over after receiving erroneous advice from a financial advisor. The taxpayer had requested…
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.