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 1122034: IRS explains the taxable and nontaxable portions of pension annuity and lump-sum payments
An individual living outside the United States asked how pension annuity payments and a related lump-sum transfer to an IRA would be treated if the individual were a U.S. resident. The IRS treated…
PLR 1122033: IRS grants late relief to recharacterize a Roth IRA conversion
An individual instructed a financial institution to convert part of a traditional IRA to a Roth IRA, but did not learn that the conversion had occurred until after the deadline for changing it. The…
PLR 1122032: IRS waives the 60-day rollover deadline after incorrect financial advice
Two retirees withdrew funds from their IRAs after their financial advisor told them they could roll the funds into their former employer's plan. The retirees later learned that they were no longer…
PLR 1122031: IRS waives the 60-day rollover deadline after a financial institution's distribution error
An individual received an IRA distribution that was larger than intended because a financial institution initiated the wrong amount. The individual returned the excess to the IRA, but the 60-day…
Determination 1122030: IRS approves a foundation's set-aside for relocating public statues
The IRS considered a private non-operating foundation's request to set aside income for relocating six public statues and, if necessary, commissioning a seventh statue. The project required…
Determination 1122029: IRS approves scholarship and therapeutic grants for children affected by abuse
The IRS approved a private foundation's procedures for making scholarships and specific objective grants to children with a history of abuse and neglect. Educational grants could fund study at…
Determination 1122028: IRS denies exemption to a spa retreat and bottled-water organization
The IRS denied tax-exempt status to an organization that planned to operate paid spa retreats, provide spiritual and health services, and manufacture and sell bottled mineral water. The IRS…
Determination 1122027: IRS denies exemption to an organization that did not establish its church status or exempt operations
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization that described itself as a church or religious organization. The organization submitted multiple inconsistent organizing…
Determination 1122026: IRS revokes a foundation's exemption after it failed to provide records
The IRS revoked a foundation's tax-exempt status under IRC § 501(c)(3) after the organization failed to respond to repeated requests for records about its receipts, expenditures, activities, and…
PLR 1122025: IRS approves a charity's sale of a long-held leased property
The IRS ruled that a charitable educational organization could sell one long-held parcel of leased real property without losing its exemption under IRC § 501(c)(3). The organization planned a…
Determination 1122024: IRS revokes exemption after missing records and returns
The IRS revoked an organization's exemption under IRC § 501(c)(3) after it failed to provide records needed to examine its books and activities. The organization also failed to file required Form…
Determination 1122023: IRS revokes exemption after private benefits and missing records
The IRS revoked an organization's exemption under IRC § 501(c)(3) after finding that its president used organizational funds for cash withdrawals, personal expenses, payments to his wife, and a…
Determination 1122022: IRS revokes exemption for an organization operating unrelated businesses
The IRS revoked an organization's exemption under IRC § 501(c)(3) because its primary activities were operating a bill-paying center, a small grocery store, and a bait shop. The IRS found that these…
CCA 1122021: Chief Counsel advice identifies the statutory tax matters partner
The Chief Counsel advice addresses who becomes the tax matters partner when an entity has no valid designation. It states that the member-manager with the largest profits interest becomes the tax…
CCA 1122020: County tax-lien foreclosure sale is not reportable under the cited provisions
Chief Counsel advice concludes that a county does not have to issue Forms 1099-S, 1099-A, or 1099-C to a former property owner after a tax-lien foreclosure sale. The advice states that IRC § 6050P…
CCA 1122019: IRS advises sending a statutory notice only to the last known address
Chief Counsel advice states that IRC § 6213 requires the IRS to send a statutory notice to the taxpayer's last known address. In the circumstances discussed, the accounting firm was not the…
CCA 1122018: Wind-farm substation equipment analyzed for the § 1603 grant
Chief Counsel advice analyzes which equipment at a wind-farm substation qualifies for the § 1603 grant for energy property. The analysis treats items 1 through 5, ending with the step-up…
CCA 1122017: Disaster-loss amendments do not shift the year for energy tax credits
Chief Counsel advice states that taxpayers amending a return only to report disaster losses should claim energy tax credits earned during the later return year. The advice adds that credits earned…
PLR 1122016: REIT eminent-domain proceeds excluded from specified qualification tests
The IRS ruled on how an amount awarded to a publicly traded REIT for property taken by eminent domain would be treated under the REIT qualification tests. The ruling holds that the claim, consisting…
PLR 1122015: IRS grants more time for a partnership basis election
The IRS granted a partnership an extension of time to make an election under IRC § 754. The partnership had timely filed its return, but the election to adjust the basis of partnership property was…
PLR 1122014: Tax-lien loan interest qualifies for REIT income tests
The IRS ruled that interest earned by a prospective REIT from tax loans can qualify for the REIT income tests when the loans are secured by real property. The loans fund property-tax payments, and…
PLR 1122013: IRS grants relief for a late S corporation election
The IRS granted relief to a corporation whose Form 2553 election to be treated as an S corporation was filed late. The corporation established reasonable cause for the late election under IRC §…
PLR 1122012: RIC's CFC subpart F income qualifies under the gross-income test
The IRS ruled that subpart F income attributed to a regulated investment company from its wholly owned controlled foreign corporation would count as qualifying income under IRC § 851(b)(2). The…
PLR 1122011: IRS grants an extension for a late section 754 election
The IRS granted a limited liability company treated as a partnership an extension of time to make an election under IRC § 754. The company's return was filed without the election after a member…
PLR 1122010: IRS grants late entity-classification elections for foreign entities
The IRS granted two foreign entities 120 days to file Form 8832 elections to be treated as associations taxable as corporations for federal tax purposes. The entities were eligible to make the…
PLR 1122009: IRS grants an estate more time to elect alternate valuation
An estate timely filed its federal estate tax return, but its executor's first tax professional did not make the alternate valuation election under IRC § 2032. A second tax professional later…
PLR 1122008: IRS grants late QSub election relief
An S corporation wholly owned a domestic subsidiary and intended to treat that subsidiary as a qualified subchapter S subsidiary, or QSub, effective on its incorporation date. The S corporation did…
PLR 1122007: IRS addresses tax effects of an early trust distribution
The beneficiaries and trustees of an irrevocable trust sought court approval to distribute part of the trust principal early to the remainder beneficiaries while leaving the balance in trust. The…
PLR 1122006: IRS grants relief for a late S corporation election
The shareholders of a corporation intended for it to be treated as an S corporation from its incorporation date, but the election was filed late. The IRS determined that the corporation had…
PLR 1122005: IRS excludes a generator-funded intertie from a utility's income
An electric utility agreed to build and own an intertie connecting a generator's facility to the utility's transmission and distribution system, with the generator paying the construction costs. The…
PLR 1122004: IRS restores S corporation status after inadvertent termination
An S corporation formed wholly owned subsidiaries that caused its S election to terminate under the rules then applicable to corporations that were members of an affiliated group. The corporation…
PLR 1122003: IRS approves separate trust shares and QSST elections
An electing small business trust held stock in an S corporation and divided its income among multiple beneficiaries under the trust terms. The IRS concluded that each beneficiary's substantially…
PLR 1122002: IRS approves a foreign subsidiary F reorganization
The IRS reviewed a completed restructuring in which a foreign subsidiary migrated its country of incorporation, a disregarded subsidiary elected to be treated as a corporation, and the former…
PLR 1122001: IRS restored S corporation status after an inadvertent shareholder transfer
The IRS considered a corporation whose S election ended when its shares were transferred to an ineligible shareholder. The corporation and its shareholders took corrective action after discovering…
Determination 1121037: IRS modified funding conditions for a pension plan’s amortization extension
The IRS conditionally approved a request to modify the terms of an earlier ruling that allowed a pension plan to amortize unfunded liabilities over an extended period. It reduced the required…
PLR 1121036: IRS waived the 60-day rollover requirement after a financial institution error
A taxpayer received a distribution from an individual retirement account and instructed a financial institution to deposit it into another IRA. The institution instead deposited the funds into a…
PLR 1121035: IRS waived rollover deadlines after a spouse's death and mental incapacity
A surviving spouse acting for a deceased taxpayer's estate asked the IRS to waive the 60-day rollover deadlines for distributions from an IRA and a retirement plan. The deceased taxpayer had…
PLR 1121034: IRS waived the 60-day rollover requirement after an account titling error
A taxpayer received a distribution from an IRA and asked a financial institution to deposit it into a rollover IRA in the taxpayer's name. An employee instead opened the account in the spouse's name…
PLR 1121033: IRS waived the 60-day rollover requirement after a financial advisor's deposit error
A taxpayer received a distribution from an IRA and asked a financial advisor to place the funds into another qualified account. The advisor instead deposited the amount into a non-IRA account at the…
Determination 1121032: IRS denied exemption to a synagogue organization because of private inurement and inadequate disclosures
The IRS issued a final adverse determination to a religious organization that sought recognition as exempt under IRC § 501(c)(3) and classification as a church. The IRS found that the organization…
PLR 1121031: IRS approved a private foundation's entrepreneurship grant program
The IRS approved a private foundation's procedures for grants to individuals who will study entrepreneurship and complete educational internships. The foundation will use a committee and objective,…
PLR 1121030: IRS approved a private foundation's high school scholarship program
The IRS approved a private foundation's scholarship procedures for high school students attending a redacted school and pursuing post-secondary education. The program selects recipients based on…
IRS determination 1121029: exemption denied to an insurance company
The IRS issued a final adverse determination that an insurance company did not qualify for exemption under IRC § 501(c)(15). The company provided commercial casualty and property insurance-type…
PLR 1121028: IRS approves a VEBA's plan to use remaining funds for employee benefits
The IRS ruled that a voluntary employees' beneficiary association (VEBA) could wind up after its sponsoring trade association ended its sponsorship and all participating employers obtained other…
IRS determination 1121027: football officials' organization loses labor exemption
The IRS proposed revoking an organization's exemption under IRC § 501(c)(5). The organization supplied football officials to a league, but its members were independent contractors who received Forms…
IRS determination 1121026: charter school's exemption revoked after dissolution and filing failures
The IRS revoked a charter school's exemption under IRC § 501(c)(3), effective December 29 of the redacted year. The school had discontinued operations, had been administratively dissolved by its…
IRS determination 1121025: private foundation exemption revoked for serving its founder
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The examination found no charitable activities or payments to the charities named in…
IRS determination 1121024: exemption revoked after years of inactivity
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization had conducted no exempt-purpose activities for several years and had no…
IRS determination 1121023: exemption revoked for failure to file required returns
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to produce documents establishing that it operated exclusively…
IRS determination 1121022: inactive private foundation loses exemption
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), effective July 1 of the redacted year. The foundation had been inactive since its inception, conducted no regular financial…
IRS determination 1121021: foreclosure consulting organization denied section 501(c)(3) exemption
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to provide foreclosure-related consulting to homeowners, lenders, and investors. The IRS concluded that the…
CCA 1121020: commercialization agreement treated as a franchise with ordinary income consequences
Chief Counsel analyzed the tax treatment of a heavily redacted commercialization transaction involving patents, know-how, agreements, and contingent payments. The advice concluded that the taxpayer…
CCA 1121019: imported truck sales distinguished under the heavy vehicle excise tax rules
Chief Counsel addressed whether a regulation example involving an exported truck conflicted with Rev. Rul. 85-95. The advice explained that the regulation example involved a taxable first retail…
CCA 1121018: general partner with the largest profits interest becomes TMP by default
Chief Counsel addressed which person could serve as the tax matters partner for two partnerships. The advice stated that Partnership Y was the tax matters partner because, without a valid…
CCA 1121017: taxpayers may request recalculation under the net interest rate rule
Chief Counsel addressed the Service’s treatment of requests under IRC § 6621(d), which can produce a net interest rate of zero in certain overpayment and underpayment situations. The advice stated…
CCA 1121016: failure-to-file penalty is not determined at the partnership level
Chief Counsel addressed whether a partnership’s failure-to-file penalty was determined under the TEFRA partnership procedures. The advice stated that IRC § 6221 applies at the partnership level to…
CCA 1121015: additional statutory-notice days do not extend the agreed limitations period
Chief Counsel addressed how to calculate the statute of limitations when the parties had an agreement under Form 872 and a state notice was later rescinded. The advice stated that the additional…
PLR 1121014: extension granted for a consolidated NOL carryback election
The IRS granted a consolidated corporate group an additional 60 days to make an election for an extended net operating loss carryback period. The group missed the original deadline after reasonably…
TAM 1121013: fuel mixture is sold under a qualifying two-party exchange
The IRS concluded that a gasoline and alcohol mixture delivered over a terminal rack under a qualifying two-party exchange agreement is “sold” for purposes of the alcohol fuel mixture credit. The…
PLR 1121012: late S corporation election treated as timely after reasonable cause was established
The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation intended to make the election effective on a specified date, but did not file the required…
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.