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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CCA 201102062: State law and the operating agreement determine signing authority
Chief Counsel advice addresses whether an individual may sign for a partnership in connection with a TEFRA question and Form 872-P. The advice states that state law and the partnership’s operating…
CCA 201102061: Form 872-IA may extend the statute for an AAR in specified circumstances
Chief Counsel advice addresses whether a Form 872-IA can extend the statute of limitations under section 6227(b) for an administrative adjustment request. The advice notes that the current forms do…
CCA 201102060: Advice on the deadline for an administrative adjustment request
Chief Counsel advice discusses the deadline for filing an administrative adjustment request. It states that the request generally must be filed within three years after the partnership return was…
CCA 201102059: Partnership dissolution does not end TEFRA procedures
Chief Counsel advice addresses the continuing application of TEFRA partnership procedures after a partnership dissolves. It states that dissolution does not end the procedures, which are analogous…
CCA 201102058: Relocation assistance does not have to be paid to the IRS for a lien discharge
Chief Counsel advice addresses whether the IRS can require a taxpayer to turn over relocation assistance as a condition of discharging a federal tax lien. It concludes that a $3,000 payment under…
CCA 201102057: Some amended-return amounts may be assessed during a TEFRA proceeding
Chief Counsel advice addresses assessments reported and paid on amended returns while a TEFRA partnership proceeding is pending. It states that amounts reported and paid on amended returns may be…
CCA 201102056: Partnership liabilities remain as reported unless adjusted
Chief Counsel advice addresses the amount, character, and allocation of partnership liabilities. It states that those items remain as reported on the partnership return unless an FPAA adjusts them…
PLR 201102055: Commodity-linked note and CFC income qualify as regulated investment company income
A regulated investment company asked whether income from a commodity-linked note would count toward the qualifying-income test and whether income from a wholly owned controlled foreign corporation…
PLR 201102054: IRS grants more time to elect disregarded-entity treatment
A foreign entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election but missed the filing…
PLR 201102053: IRS grants more time to allocate a deceased spouse’s GST exemption
A grantor and spouse made gifts to an irrevocable trust and elected to treat the gifts as made one-half by each spouse. Their accounting firm prepared the gift tax returns but failed to allocate the…
PLR 201102052: Trust settlement avoids transfer taxes and gain recognition
A family sought rulings on the federal tax effects of a mediated settlement involving two trusts created under a decedent’s will. The settlement resolved long-running disputes involving the rule…
PLR 201102051: IRS approves a settlement of disputed trust interests without additional tax recognition
A family settled a long-running dispute over how two trusts should distribute income and principal to descendants. The settlement used a negotiated fractional split between competing per capita and…
CCA 201102050: Nuclear-waste fee deductions do not create a specified liability loss
Chief Counsel advice considers whether a nuclear power company’s periodic payments under the Nuclear Waste Policy Act of 1982 can generate a specified liability loss under section 172(f). The advice…
PLR 201102049: IRS grants late S corporation election relief for reasonable cause
A corporation intended to elect S corporation status for its first tax year but did not timely file Form 2553. The IRS determined that the corporation had reasonable cause for the late election. It…
PLR 201102048: IRS grants late entity-classification and S corporation election relief
A limited liability company intended to be treated as an S corporation from a stated effective date but failed to timely file Forms 8832 and 2553. The IRS granted the company 120 extra days to elect…
PLR 201102047: Subpart F income from a wholly owned CFC qualifies for a RIC income test
A regulated investment company planned to invest through a wholly owned foreign subsidiary in commodities and related derivatives. Because the subsidiary was expected to be a controlled foreign…
PLR 201102046: IRS approves a tax-free corporate separation with S corporation elections
Two shareholders planned to separate two business lines by having an existing corporation transfer assets and liabilities to a newly formed corporation, then distribute the new corporation’s stock…
PLR 201102045: IRS permits a retroactive QEF election for an undisclosed PFIC investment
A U.S. taxpayer indirectly owned shares in a passive foreign investment company through foreign trusts but did not know the investment existed. The taxpayer and several advisers provided affidavits…
PLR 201102044: IRS permits a retroactive QEF election after a PFIC interest was undisclosed
A U.S. taxpayer indirectly acquired an interest in a passive foreign investment company through foreign trusts, without receiving enough information to identify the investment or its PFIC status.…
PLR 201102043: IRS allows a late S corporation election after reasonable cause was established
The taxpayer intended for its corporation to be treated as an S corporation beginning on a specified date, but it did not timely file Form 2553. The IRS concluded that the corporation had reasonable…
PLR 201102042: IRS grants relief for a late S corporation election
The corporation's shareholders intended for it to be an S corporation beginning on a specified date, but the corporation did not timely file Form 2553. The IRS concluded that the corporation…
PLR 201102041: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102040: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102039: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102038: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102037: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102036: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102035: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 201102034: IRS restores S corporation status after an untimely QSST election
A corporation's S corporation election terminated after stock was transferred to a trust and the beneficiary did not timely file a qualified subchapter S trust (QSST) election. The IRS concluded…
PLR 201102033: IRS preserves S corporation status after disproportionate distributions
The corporation made disproportionate distributions to its shareholders even though its governing documents provided identical distribution and liquidation rights. The IRS explained that the…
PLR 201102032: IRS grants extensions for entity classification and S corporation elections
The limited liability company intended to be treated as an association taxable as a corporation and as an S corporation, but it failed to timely file Forms 8832 and 2553. The IRS granted the company…
PLR 201102031: IRS grants more time to make an investment-income election
The taxpayers had investment interest expense and net capital gains, but their accountant did not make the election under IRC § 163(d)(4)(B) to treat part of the net capital gain as investment…
PLR 201102030: IRS approves a revised nuclear decommissioning funding schedule
The taxpayer requested a revised schedule of ruling amounts for contributions to a nuclear decommissioning reserve fund. The IRS concluded that the taxpayer had a qualifying interest in the nuclear…
PLR 201102029: IRS approves a special nuclear decommissioning transfer and deduction schedule
The taxpayer requested an initial schedule of deduction amounts for a special transfer to a nuclear decommissioning fund, together with a revised schedule of ruling amounts. The IRS concluded that…
PLR 201102028: IRS grants extensions for association and S corporation elections
The limited liability company intended to be treated as an association taxable as a corporation and as an S corporation, but it failed to timely file Forms 8832 and 2553. The IRS granted the company…
PLR 201102027: IRS treats proposed compressed natural gas sales as bulk sales
An independent energy company planned to sell compressed natural gas to commercial users and government transportation operations through fueling stations that would not be open to the general…
PLR 201102026: IRS grants a partnership more time to make a section 754 election
A limited partnership asked for extra time to make a section 754 election after a partner died and the partnership missed the filing deadline. The IRS granted an extension of 120 days from the date…
PLR 201102025: IRS grants an LLC more time to make a section 754 election
A limited liability company treated as a partnership for federal tax purposes asked for extra time to make a section 754 election after a partner died and the company missed the filing deadline. The…
PLR 201102024: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102023: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102022: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102021: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102020: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102019: IRS approves tax treatment of a settlement dividing a family trust
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust created under a decedent's will. The settlement divided the…
PLR 201102018: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102017: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102016: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102015: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102014: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102013: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102012: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102011: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102010: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102009: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102008: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102007: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102006: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102005: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102004: IRS approves tax treatment of a settlement resolving family trust distribution disputes
A family sought rulings on the federal tax consequences of a court-approved settlement resolving disputes over how a trust created under a decedent's will should be distributed. The settlement…
PLR 201102003: IRS distinguishes importer status for patented and non-patented archery equipment
A domestic corporation planned to buy archery equipment made abroad through an unrelated import broker, then brand, package, and sell the products in the United States. The IRS ruled that the…
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.