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 1117043: IRS waives the 60-day IRA rollover deadline after a financial institution error
The IRS considered a taxpayer who intended to transfer an IRA certificate of deposit into a new IRA but whose financial institution opened a non-IRA account instead. The taxpayer discovered the…
PLR 1117042: IRS waives the 60-day IRA rollover deadline for a transfer into a special needs trust
The IRS considered a disabled taxpayer whose IRA funds were transferred into a trust account after a court authorized a special needs trust. The financial institution could not establish an IRA in…
PLR 1117041: IRS waives the 60-day IRA rollover deadline after a bank deposits funds into a non-IRA account
The IRS considered a 73-year-old taxpayer who intended to move funds from one IRA into an IRA certificate of deposit at a bank. An employee instead deposited the distribution into a non-IRA account,…
PLR 1117040: IRS waives the 60-day rollover deadline for an excess IRA distribution caused by an adviser error
The IRS considered a taxpayer whose financial adviser mistakenly directed an IRA distribution larger than the required minimum distribution. The taxpayer tried to redeposit the excess after learning…
PLR 1117039: IRS waives the 60-day rollover deadline after a Ponzi scheme made the funds unrecoverable
The IRS considered a married couple who took distributions from two IRAs to move the funds into more conservative investments. After fees were withheld, they deposited the net amounts into an…
PLR 1117038: IRS waives the 60-day rollover deadline after a broker misappropriates IRA funds
The IRS considered a taxpayer who closed several IRAs and annuities to consolidate the funds into rollover accounts. The taxpayer gave the distribution checks to a financial adviser, who prepared…
PLR 1117037: IRS grants late recharacterization relief after a tax preparer discovers Roth IRA errors
The IRS considered a married couple whose income exceeded the limits for a Roth IRA conversion and some regular Roth IRA contributions. Their CPA discovered the problem only after the deadline for…
IRS denies tax-exempt status to a fee-based bankruptcy counseling organization
The IRS denied section 501(c)(3) exemption to an organization that planned to provide bankruptcy counseling and related online services for fees. The determination found that the organization had a…
IRS revokes exemption for a dog club focused on shows and obedience training
The IRS revoked a dog club’s section 501(c)(3) exemption after concluding that its primary activities were dog shows, sanctioned matches, and obedience training. The determination found that the…
PLR 1117034: Organizational amendments did not affect a charity's tax-exempt status
An organization supporting people with neurological impairment asked whether changes to its organizational documents would affect its section 501(c)(3) exemption. The changes removed one exempt…
CCA 1117033: Mailing to a recipient's current residence was not a disclosure violation
Chief Counsel Advice addressed whether mail could continue to be sent to a person's home address when the mail was apparently forwarded to the person's current residence. The advice stated that…
CCA 1117032: A dissolved LLC's authority to sign a statute extension depends on state law
Chief Counsel Advice addressed who should sign a statute extension for an LLC acting as a withholding agent. The advice stated that the extension would be in the LLC's name and typically signed by a…
CCA 1117031: The IRS had to release a premature wage levy and offer to return recent proceeds
Chief Counsel Advice addressed a continuous wage levy issued before the taxpayer received valid collection due process rights after assessment. The advice concluded that the premature levy violated…
CCA 1117030: A disregarded LLC's property could not be levied for its sole member's tax debt
Chief Counsel Advice confirmed that the IRS could not levy on property owned by a disregarded LLC to satisfy the tax liability of the LLC's sole member. The advice explained that the sole member had…
CCA 1117029: IRS files could not be used to distribute a public Tax Court memo
Chief Counsel Advice addressed whether IRS employees could give members of a law school tax procedure class a copy of a Tax Court trial memorandum that was already part of the court's public record.…
TAM 1117028: CO2 equipment costs were not deductible under section 193, but retroactive application was limited
The IRS considered whether an oil and gas company could deduct the costs of CO2 transportation assets, including pipelines, and CO2 injection and recycling facilities as qualified tertiary injectant…
TAM 1117027: A managed-care HMO was taxable as an insurance company
The IRS considered whether a managed-care HMO was subject to the insurance-company tax rules in Part II of Subchapter L. The HMO arranged health care through provider networks, received fixed…
CCA 1117026: Non-NRSA research-fellow payments were wages subject to FICA
Chief Counsel Advice addressed whether payments to non-NRSA research fellows under non-NRSA research grants were wages subject to FICA taxes. The IRS distinguished those payments from cost-of-living…
PLR 1117025: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
PLR 1117024: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
PLR 1117023: Consolidated group received more time to elect an extended NOL carryback
The IRS granted a consolidated corporate group an extension of time to elect an extended carryback period for a net operating loss. The group had filed Form 1139 but had not made a valid…
PLR 1117022: Acquiring consolidated group received more time to waive a prior-group NOL carryback
The IRS granted an acquiring consolidated group 45 days from the ruling date to make an election waiving the portion of the net operating loss carryback period attributable to subsidiaries’…
PLR 1117021: Tax refund interest was interest, while related gain was not subject to withholding
The IRS ruled on the tax treatment of anticipated federal and state tax refunds held through a liquidating trust for creditors of bankrupt companies. It concluded that stated interest on the refund…
PLR 1117020: Corporation received permission to reelect S status before the five-year wait ended
The IRS permitted a corporation to reelect S corporation status before the five-year waiting period normally imposed after a prior S election terminates. The prior election ended when the…
PLR 1117019: IRS allows more time to request revised nuclear decommissioning fund ruling amounts
The taxpayer owned an interest in a nuclear power plant and had received a schedule of ruling amounts for its qualified decommissioning fund. After the Nuclear Regulatory Commission extended the…
PLR 1117018: IRS grants late-election relief for foreign entity classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make that…
PLR 1117017: Subsidiaries were treated as joining the parent’s consolidated return
The IRS determined that two subsidiaries joined their parent’s initial consolidated federal income tax return even though Forms 1122 were not filed for them. The subsidiaries’ income and deductions…
PLR 1117016: S corporation status continued after mistaken trust distributions
The IRS determined that an S corporation’s election was inadvertently terminated after stock was distributed among trusts in a way that did not match the governing will and trust instruments. The…
PLR 1117015: S corporation status continued after an ineligible shareholder transfer
The IRS determined that an S corporation’s election was inadvertently terminated when an ineligible shareholder acquired shares. After the problem was discovered, an eligible shareholder acquired…
PLR 1117014: Reward points did not trigger information reporting
The IRS ruled that a company did not have to file information returns for reward points offered to enrollees in a voluntary discount program. The points were not transferable, could not be redeemed…
PLR 1117013: Variable annuity certificate treatment for an investment account
The IRS ruled on the federal tax treatment of a proposed certificate linked to an investment account and designed to provide a future annual benefit if the account were depleted under specified…
PLR 1117012: Annuity certificate treatment for an investment account
The IRS ruled on a proposed certificate linked to an investment account that would provide an annual benefit if the account were depleted under specified conditions. It concluded that the group…
PLR 1117011: Extension of time to elect single rental real estate activity
The IRS considered a taxpayer's request to treat all interests in rental real estate as one activity for passive activity purposes. The taxpayer qualified for the real property business exception…
PLR 1117010: Relief for a late S corporation election
The IRS considered a corporation's request to be treated as an S corporation from its incorporation date even though its election was filed late. The IRS found that the corporation had reasonable…
PLR 1117009: Tax treatment of a six-way family-business split-up
The IRS ruled on a closely held corporation's plan to separate one business among six family shareholder groups. The corporation would transfer business assets to six newly formed corporations,…
PLR 1117008: Relief for an inadvertent S corporation termination
The IRS considered an S corporation whose shareholder trust did not timely make the election required for a qualified subchapter S trust. The IRS concluded that the S corporation election terminated…
PLR 1117007: Deductibility of a settlement payment to banking clients
The IRS considered whether a financial-services company could deduct a settlement payment made to clients affected by an investment fund fraud. The payment was made through a contribution to a…
PLR 1117006: Tax refund interest and withholding on related gain
The IRS considered a bankruptcy-related liquidating trust that would hold tax refund claims and distribute the proceeds to creditors, many of whom could be non-U.S. persons. The IRS ruled that…
PLR 1117005: QTIP trust and charitable remainder unitrust provisions
The IRS considered proposed amendments to a revocable trust that would create a QTIP trust for the taxpayer's spouse and a charitable remainder unitrust. It ruled that the QTIP trust could qualify…
PLR 1117004: Relief for a missed ESBT election
The IRS considered an S corporation whose stock was transferred to a trust after a shareholder's death. The trust did not timely elect to be treated as an electing small business trust, which…
PLR 1117003: Extension for a late disregarded-entity election
The IRS considered a foreign eligible entity that intended to be treated as disregarded for federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief…
PLR 1117002: Foreign pension entity classified as a trust for federal tax purposes
The IRS considered whether an entity formed under foreign law to provide disability, old age, and death benefits to covered employees and their beneficiaries should be classified as a trust for…
PLR 1117001: Amendments to grandfathered deferred compensation plans do not trigger section 457
The IRS considered proposed amendments to substantially similar deferred compensation plans maintained by a tax-exempt organization. The plans were established before the 1986 changes to section 457…
Other 1116046: IRS revoked a section 501(c)(3) exemption for inactivity and private benefit
The IRS issued a final adverse determination revoking an organization's tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The IRS said the organization was not operated exclusively for an…
PLR 1116045: Five-year extension approved for amortizing an underfunded pension plan's liabilities
The IRS approved a request for a five-year automatic extension to amortize a pension plan's unfunded liabilities as of January 1, 2010. The extension applies to eligible amortization charge bases…
PLR 1116044: IRS waived the 60-day rollover deadline after an advisor misappropriated IRA distributions
The IRS considered a taxpayer's request to waive the 60-day rollover requirement after a financial advisor misappropriated distributions from three IRAs. The taxpayer had intended to consolidate the…
PLR 1116043: IRS waived rollover deadlines after fraud involving an IRA and annuity
The IRS considered a taxpayer's request to waive the 60-day rollover requirements for distributions from an IRA and an annuity. The taxpayer intended to roll both distributions into replacement…
PLR 1116042: IRS waived the 60-day IRA rollover deadline after an advisor's fraud
The IRS considered a taxpayer's request to waive the 60-day rollover requirement for distributions from three IRAs. The taxpayer intended to consolidate the accounts and deposit the distributions…
PLR 1116041: IRS waived the 60-day IRA rollover deadline after an advisor's fraud
The IRS considered a taxpayer's request to waive the 60-day rollover requirement for distributions from two IRAs. The taxpayer intended to consolidate the accounts and deposit the distributions into…
PLR 1116040: IRS waived the 60-day IRA rollover deadline after fraud and bank refusals
The IRS considered a taxpayer's request to waive the 60-day rollover requirement after the taxpayer recovered funds from an investment fraud. The recovered amount included both IRA and non-IRA…
Determination 1116039: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applied to eligible amortization charge bases…
Determination 1116038: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applied to eligible amortization charge bases identified…
Determination 1116037: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applied to eligible amortization charge bases identified…
Determination 1116036: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of April 1, 2010. The extension applied to eligible amortization charge bases identified…
Determination 1116035: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applied to eligible amortization charge bases identified…
Determination 1116034: IRS approved a five-year extension for unfunded plan liabilities
The IRS approved a request for a five-year automatic extension to amortize a plan's unfunded liabilities as of January 1, 2010. The extension applied to eligible amortization charge bases…
Determination 1116033: IRS revoked a section 501(c)(3) exemption after recordkeeping failures
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The IRS said the organization failed to produce documents showing that it operated exclusively for…
Determination 1116032: IRS revoked a section 501(c)(3) exemption for recordkeeping failures
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to meet the recordkeeping and reporting requirements under IRC §§ 6001 and…
Determination 1116031: IRS revoked an exemption while private-foundation filing duties continued
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to establish that it operated exclusively for exempt purposes and did not…
Determination 1116030: IRS denied exemption to a brand-specific dealer advertising organization
The IRS denied tax exemption under IRC § 501(c)(6) to an organization formed by dealers of particular vehicle brands. The organization used cooperative advertising contributions to promote those…
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.