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 201051027: IRS declines to waive the WRERA 180-day airline payment rollover deadline
An airline employee received a payment after the airline's qualified retirement plan was terminated in bankruptcy and asked to transfer it to a Roth IRA under section 125 of WRERA. The employee…
PLR 201051026: IRS waived the 60-day IRA rollover requirement after the taxpayer's spouse died
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from an IRA and did not complete the rollover on time after the sudden and unexpected death of the…
PLR 201051025: IRS approves a make-up IRA payment without treating it as a modification
An individual under age 59½ received substantially equal periodic payments from an IRA under the exception in IRC § 72(t)(2)(A)(iv). The custodian missed one monthly payment after changing the…
IRS denies § 501(c)(3) exemption to a church-affiliated lending institution
The IRS issued a final adverse determination to an organization formed by members of several churches to provide loans and investment opportunities to church members. The organization argued that…
PLR 201051023: Trust settlement will not trigger GST, gift, estate, or income tax
The IRS considered a proposed settlement of litigation over two trusts created under a deceased person's will. The dispute concerned the rule against perpetuities, how trust principal and income…
PLR 201051022: IRS grants extra time to waive a consolidated NOL carryback
A consolidated corporate group failed to timely file an election to relinquish the entire carryback period for a consolidated net operating loss. The group requested relief under the regulatory…
CCA 201051021: Divorced parents may both claim a child as a dependent for § 139D benefits
Chief Counsel Advice addresses whether divorced, separated, or apart-living parents who are members of an Indian tribe may both treat their child as a dependent for purposes of IRC § 139D. The…
PLR 201051020: Foreign stock exchange gain may count toward loss limitation
A consolidated corporate group in bankruptcy proposed to move foreign subsidiary stock to a new disregarded LLC and then transfer the LLC interests to creditors. The IRS ruled that the resulting…
PLR 201051019: Bankruptcy reorganization rules for section 382 loss limits
A consolidated corporate group emerged from a Chapter 11 bankruptcy after a plan exchanged creditors’ claims for new debt, stock, or other rights. The IRS ruled that the group could use the…
PLR 201051018: Taxpayer granted more time to make an RRSP election
A Canadian citizen who became a United States resident did not know that a Form 8891 election was needed to defer U.S. tax on income accrued in Canadian RRSP accounts. The taxpayer asked for more…
PLR 201051017: Late S corporation election treated as timely
A corporation intended to elect S corporation status when it was incorporated but did not timely file Form 2553. The IRS determined that the corporation had reasonable cause for the late election.…
PLR 201051016: Omitted Form 1122 forms treated as filed
A corporate group filed its first consolidated return after a reorganization but accidentally omitted Forms 1122 for multiple subsidiaries and LLCs. The members were listed on Form 851, their income…
PLR 201051015: Inadvertently late S corporation election treated as timely
A corporation intended to elect S corporation status but inadvertently filed Form 2553 late. The IRS concluded that the corporation had reasonable cause for the failure. It allowed the corporation…
PLR 201051014: CFC subpart F income may qualify for a RIC income test
A regulated investment company planned to invest in a wholly owned foreign subsidiary that would trade in commodities, futures, swaps, and related instruments. The subsidiary was expected to be a…
PLR 201051013: Late disregarded-entity election granted extra time
A foreign entity with one owner intended to be treated as a disregarded entity for U.S. federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief under…
PLR 201051012: Late S corporation election relief granted
A corporation intended to be treated as an S corporation but did not timely file the required election. The IRS concluded that the corporation had reasonable cause for the failure and qualified for…
PLR 201051011: Late S corporation election relief granted
A corporation intended to be treated as an S corporation but did not timely file the required election. The IRS concluded that the corporation had reasonable cause for the failure and qualified for…
PLR 201051010: S corporation status preserved after possible termination
An S corporation’s shareholder engaged in an event that may have inadvertently terminated the corporation’s S election. The corporation represented that the event was not motivated by tax avoidance,…
PLR 201051009: Late S corporation election treated as timely
A corporation’s sole shareholder intended for it to be an S corporation, but Form 2553 was not timely filed. The IRS found reasonable cause for the late election and granted relief under IRC…
PLR 201051008: S corporation election cured after missing shareholder consents
A corporation attempted to elect S corporation status, but two shareholders did not provide the required consents. The IRS ruled that the election was ineffective because of the missing consents,…
PLR 201051007: Late entity-classification and S corporation elections allowed
An LLC intended to be treated as an S corporation but failed to timely file its entity-classification and S corporation election forms. The IRS granted the LLC 120 days to file Form 8832 and treat…
PLR 201051006: Revised nuclear decommissioning funding schedule approved
A nuclear power plant owner requested a revised schedule of ruling amounts for its qualified nuclear decommissioning reserve fund after the plant's operating license was extended. The IRS concluded…
PLR 201051005: Extension granted to file duplicate Form 3115
A taxpayer timely filed its federal income tax return and original Form 3115 to change an accounting method, but its signed duplicate Form 3115 reached the accounting firm too late to be filed with…
PLR 201051004: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 201051003: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 201051002: Trust settlement receives favorable federal tax treatment
A family sought IRS rulings on the federal tax consequences of a court-approved settlement resolving disputes over the distribution of a trust holding stock. The settlement divided the trust into…
PLR 201051001: Extension granted to file duplicate Form 3115
A taxpayer timely filed its federal income tax return and original Form 3115 to change an accounting method for personal property taxes, but its signed duplicate Form 3115 reached the accounting…
PLR 201050045: IRS waives 60-day IRA rollover deadline
A taxpayer withdrew money from an IRA after a financial institution employee incorrectly said the rollover period was 90 days. The taxpayer missed the 60-day deadline but kept the distribution in a…
PLR 201050044: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
PLR 201050043: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
PLR 201050042: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
IRS determination 201050041: Exempt status revoked for failure to substantiate operations
The IRS revoked an organization's exemption under IRC § 501(c)(3) after the organization failed to produce records establishing that it operated exclusively for exempt purposes and that its earnings…
IRS determination 201050040: Exemption revoked for business league providing particular services
The IRS revoked a tax-exempt organization’s status under IRC § 501(c)(6). The organization served businesses in different industries and primarily provided human-resources information and consulting…
IRS determination 201050039: Exemption revoked for seller-funded down payment assistance program
The IRS revoked an organization’s exemption under IRC § 501(c)(3), retroactive to the date it began operating a seller-funded down payment assistance program. The program was open to home buyers…
IRS determination 201050038: Exemption revoked after organization failed to document dissolution
The IRS revoked an organization’s exemption under IRC § 501(c)(3), effective on a redacted date. The organization said it was dissolving but did not provide Articles of Dissolution, records showing…
Other 201050037: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) tax-exempt status. The IRS found that the organization did not operate exclusively for exempt purposes,…
IRS determination 201050036: Exemption revoked for fraternal organization operating commercial bar
The IRS concluded that a subordinate fraternal organization did not qualify for exemption under IRC § 501(c)(10). The organization operated a public bar, received substantially all of its income…
IRS determination 201050035: Exemption revoked after organization failed to provide examination records
The IRS revoked an organization’s exemption under IRC § 501(c)(3) after it repeatedly failed to provide records and information needed for an examination. The organization did not schedule an…
IRS determination 201050034: Exemption revoked for fraternal organization operating video lottery facility
The IRS recommended revoking a fraternal organization’s exemption under IRC § 501(c)(10). The organization’s roughly 250 members were allowed to join by completing a membership card to play video…
IRS determination 201050033: Exemption denied for gymnastics fundraising association
The IRS denied an application for exemption under IRC § 501(c)(3) by an association that raised money to offset the costs of children participating in a competitive gymnastics program at a…
CCA 201050032: Disclosures may support the sale of seized assets
Chief Counsel Advice considered whether the IRS could disclose information needed to conduct a sale of seized assets. It concluded that IRC § 6103(k)(6) and Treas. Reg. § 301.6103(k)(6)-1(a)(1)…
CCA 201050031: A net operating loss election could not be revoked without the related WHBAA election
Chief Counsel Advice considered whether a taxpayer could revoke an election under IRC § 172(b)(3) to waive the net operating loss carryback period. The advice explained that the election could be…
CCA 201050030: Notice delivery to a power of attorney can affect collection challenges
Chief Counsel Advice addressed whether a taxpayer could challenge an underlying tax liability during a Collection Due Process hearing when a Notice of Deficiency was sent to a power of attorney.…
CCA 201050029: Joint-return information may be disclosed while liability remains unresolved
Chief Counsel Advice considered whether the IRS could disclose a purported joint return and related return information to one spouse when that spouse claimed not to have signed the return. The…
PLR 201050028: Late S corporation election treated as timely for reasonable cause
The IRS granted relief to a small business corporation whose shareholder intended to make an S corporation election effective on a specified date, but the election was not filed on time. The IRS…
PLR 201050027: Grain payments treated as per-unit retain allocations paid in money
The IRS ruled for a farmers’ cooperative that made payments to members for grain marketed through the cooperative. It concluded that the payments were per-unit retain allocations paid in money under…
PLR 201050026: Extension granted for a late section 338 election
The IRS granted a purchaser additional time to file a section 338(g) election after the statutory deadline had passed. The purchaser showed that it acted reasonably and in good faith, and the IRS…
PLR 201050025: Inadvertent S corporation termination disregarded
The IRS ruled that a corporation’s S corporation election was inadvertently terminated when two ineligible shareholders acquired stock. The shareholders later redeemed their interests, leaving the…
PLR 201050024: Late S corporation election treated as timely
The IRS granted relief to a company whose Form 2553 was not filed by the deadline for an intended S corporation election. It found that the company had reasonable cause for the late filing under IRC…
PLR 201050023: Extension granted for a rental real estate activity election
The IRS granted married taxpayers additional time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers represented that they were…
PLR 201050022: Extension granted for a rental real estate activity election
The IRS granted married taxpayers additional time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers represented that they were…
PLR 201050021: IRS restored an S corporation election after missed QSST elections
The IRS ruled that a corporation's S corporation election was inadvertently terminated when six trusts received its stock and their beneficiaries did not make the required Qualified Subchapter S…
PLR 201050020: IRS approved a corporate recapitalization and Type F reorganization
The IRS ruled on a proposed restructuring of a publicly traded parent's foreign holding-company structure. The plan included a recapitalization of a foreign subsidiary's common and preferred stock,…
PLR 201050019: IRS disregarded an inadvertent S corporation termination
The IRS ruled that a corporation's S corporation election was inadvertently terminated when a trust became a shareholder without filing a timely QSST election. The corporation represented that the…
PLR 201050018: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended the election to…
PLR 201050017: IRS classified a state-created association as a division, not a political subdivision
The IRS considered whether a state-created association administering a no-fault medical compensation plan was a political subdivision of the state. The IRS concluded that the association did not…
PLR 201050016: IRS allowed a late S corporation election effective from incorporation
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended S corporation…
PLR 201050015: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended S corporation…
PLR 201050014: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, intended S corporation treatment from its…
PLR 201050013: IRS approved Type D reorganizations and tax-free stock distributions
The IRS approved a proposed restructuring by an S corporation that would transfer the Business1 assets and other assets proportionally to two newly formed corporations, while Distributing continued…
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.