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 1047029: IRS waived the 60-day IRA rollover deadline after a financial institution's error
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer intended to move the funds to an IRA at another financial institution, but the receiving…
PLR 1047028: IRS waived the 60-day IRA rollover deadline after misleading information
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. A representative of the taxpayer's financial institution incorrectly said that the taxpayer had 90…
PLR 1047027: IRS waived the 60-day IRA rollover deadline after errors by financial professionals
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another tax-deferred retirement account. After the taxpayer's husband died, she relied on financial professionals,…
Determination 1047026: IRS approved a private foundation's scholarship grant-making procedures
The IRS approved a private foundation's procedures for awarding scholarships to eligible primary, secondary, undergraduate, and graduate students. The program uses a selection committee and…
Determination 1047025: IRS approved a private foundation's set-aside for an overseas education project
The IRS approved a private operating foundation's set-aside of funds for a project providing educational materials and teacher training to indigenous communities in a foreign country. The foundation…
Determination 1047024: IRS denied exemption to a cooperative charitable insurance pool
The IRS issued a final adverse determination denying tax-exempt status under section 501(c)(3) to a cooperative self-insurance pool for charitable organizations. The organization received its…
PLR 1047023: IRS ruled on section 304 and section 351 treatment for a multinational restructuring
The IRS ruled on the federal tax consequences of a proposed restructuring involving a foreign partnership, several foreign corporations, and newly formed companies. The ruling addressed exchanges…
CCA 1047022: The pre-AJCA section 6707 penalty is not subject to the section 6501 limitations period
Chief Counsel Advice considered whether the three-year assessment period in IRC § 6501 applies to the pre-AJCA penalty for failing to register a tax shelter under former IRC § 6707(a)(1). The advice…
CCA 1047021: Estate beneficiaries could not claim unused capital loss carryovers after the estate transferred all property to the United States
Chief Counsel Advice considered whether an estate's residuary beneficiaries could use the estate's unused capital loss carryovers under IRC § 642(h)(1). The estate was insolvent under a settlement…
CCA 1047020: LIHEAP participants, not vendors, could claim refunds for tax on kerosene used for home heating
Chief Counsel Advice considered whether undyed kerosene purchased with state vouchers under the Low Income Home Energy Assistance Program was for the exclusive use of a state. It concluded that the…
PLR 1047019: Life company mergers would not be disproportionate asset acquisitions for consolidated return purposes
The IRS issued a supplemental ruling on a proposed combination of two U.S. consolidated groups under a foreign parent. The transaction involved mergers of parent companies and life insurance…
PLR 1047018: An inadvertent QSST failure did not terminate the corporation's S election
The IRS considered an S corporation whose shareholder trust stopped qualifying as a Qualified Subchapter S Trust because it failed to distribute all of its income to the beneficiary. The trust later…
PLR 1047017: A city employee health-benefit trust qualified for the section 115 income exclusion
The IRS ruled on a trust established by a city to fund hospital, surgical, and health insurance coverage for retired city employees and their families. Only the city could contribute, private…
PLR 1047016: A multi-step corporate separation received specified reorganization and nonrecognition treatment
The IRS ruled on a proposed separation of businesses involving a publicly traded parent, domestic and foreign subsidiaries, an internal spinoff, a subsidiary liquidation, a contribution of assets to…
PLR 1047015: The IRS permitted an early reelection of the foreign earned income exclusion
The IRS permitted a taxpayer to reelect the foreign earned income exclusion under IRC § 911 before the normal waiting period ended. The taxpayer had revoked the election, returned to the United…
PLR 1047014: The IRS allowed a late S-corporation election for reasonable cause
The IRS considered a corporation that intended to elect S-corporation status but did not timely file Form 2553. Based on the submitted facts and representations, the IRS found reasonable cause for…
PLR 1047013: The IRS granted more time to make a section 754 election
The IRS granted a partnership an extension of time to make a section 754 election after the partnership’s accountant inadvertently failed to file it. The partnership had timely filed its returns and…
PLR 1047012: A state residual property-insurance association qualified for the section 115 income exclusion
The IRS ruled that a state-created residual property-insurance association performed an essential governmental function and that its income accrued to the state. The association provided catastrophe…
PLR 1047011: A city retiree health subsidy trust qualified for section 115 treatment and had no filing requirement
The IRS ruled on a city trust that funded an implicit rate subsidy so retired city employees could pay the same health insurance premiums as current employees. The trust was funded and controlled by…
PLR 1047010: The IRS approved nuclear decommissioning deduction and ruling schedules
The IRS approved revised schedules for a taxpayer’s contributions to a qualified nuclear decommissioning fund under IRC § 468A. The ruling allowed a special transfer of a specified amount for…
PLR 1047009: IRS approves a revised nuclear decommissioning funding schedule
The IRS considered a wholly owned subsidiary's request for a revised schedule of ruling amounts for contributions to a nuclear decommissioning reserve fund. The taxpayer owned a qualifying interest…
PLR 1047008: IRS approves a revised nuclear decommissioning funding schedule
The IRS considered a wholly owned subsidiary's request for a revised schedule of ruling amounts for contributions to a nuclear decommissioning reserve fund. The taxpayer owned a qualifying interest…
PLR 1047007: IRS permits an early qualified subsidiary S election after a prior revocation
The IRS considered whether a corporation could make a qualified subchapter S subsidiary election before the five-year waiting period that generally follows termination of an earlier S election. The…
PLR 1047006: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company said its shareholders intended the election to be effective on a…
PLR 1047005: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on its incorporation date.…
PLR 1047004: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on its incorporation date.…
PLR 1047003: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on its incorporation date.…
PLR 1047002: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on its incorporation date.…
PLR 1047001: IRS grants relief for a late S corporation election
The IRS considered a company's request for relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on its incorporation date.…
PLR 1046020: IRS waives the 60-day rollover requirement after an erroneous tax withholding
The IRS considered a taxpayer's request to waive the 60-day rollover requirement after a broker mistakenly caused tax withholding from an individual retirement account distribution. The taxpayer…
IRS determination 1046019: conditional waiver of the section 4971 tax after withdrawal of a funding-standard request
The IRS closed a company's request for a waiver of the minimum funding standard after the company withdrew that request. It separately granted a conditional waiver of the 100 percent tax under…
PLR 1046018: IRS approves a private foundation's professional development grant program
The IRS reviewed a private foundation's proposed grant program to support professional development for employees of its nonprofit grantee organizations. The grants could fund conferences, workshops,…
PLR 1046017: IRS approves a private foundation's scholarship program
The IRS reviewed a private foundation's proposed scholarship program for deserving young women who would attend a specified university. The program used a selection committee, objective eligibility…
IRS determination 1046016: organization denied section 501(c)(3) exemption for commercial restaurant activities
The IRS issued a final adverse determination denying a nonprofit organization's application for recognition under section 501(c)(3). The organization planned to operate a large restaurant,…
CCA 1046015: IRS modifies advice on identifying section 1256 contracts as hedges
Chief Counsel advice modified an earlier conclusion about whether certain section 1256 contracts could receive ordinary treatment as hedging transactions. The advice stated that section 1256(f)(2)…
CCA 1046014: advice on income limits and certifications for a low-income housing project
Chief Counsel advice addressed whether a low-income housing project used the correct income limits for determining tenant eligibility and whether the project could lose section 42 credits because…
PLR 1046013: solar and smart-grid property provided by a utility is excluded from customer income
The IRS ruled that a regulated utility's pilot program could provide smart-grid equipment, solar photovoltaic systems, and battery storage to residential customers without causing the value of that…
PLR 1046012: foreign entity granted additional time to elect disregarded-entity status
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 intended the election to be…
PLR 1046011: S corporation election restored after inadvertent passive-income termination
The IRS ruled that a corporation's S corporation election terminated because it had accumulated earnings and profits and passive investment income exceeding 25% of gross receipts for three…
CCA 1046010: separately stated 911 fees are not subject to the communications excise tax
Chief Counsel advice concluded that mandatory 911 and E911 fees separately stated on communications bills are not subject to the federal communications excise tax. Section 4254(c) excludes a…
CCA 1046009: advice on offsetting and calculating look-back interest
Chief Counsel advice addressed how the Service should handle look-back interest payable to a taxpayer under the long-term contract percentage-of-completion method. It concluded that the government…
PLR 1046008: life insurance rider does not alter section 7702 calculations
The IRS ruled that a rider on flexible-premium variable universal life insurance policies could provide guaranteed annual withdrawals or loans without changing the policies' section 7702…
PLR 1046007: taxpayer granted more time to elect amortization of drilling and exploration costs
The IRS granted a taxpayer 120 additional days to elect under section 59(e) to amortize intangible drilling and development costs and exploration costs for three prior tax years. The taxpayer's…
PLR 1046006: corporation granted relief for late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file Form 2553 to elect S corporation status. The corporation's sole shareholder intended the election to be effective on…
PLR 1046005: S corporation status preserved after transfer to an ineligible shareholder
The IRS ruled that a corporation's S corporation election terminated when it inadvertently issued shares to an IRA, which was an ineligible shareholder. The corporation promptly redeemed the shares…
PLR 1046004: settlement distributions to surviving spouse qualify for estate tax marital deduction
The IRS ruled that property distributed to a surviving spouse under a settlement agreement qualified for the federal estate tax marital deduction. The decedent's revocable trust and marital…
PLR 1046003: late partnership classification election receives a 120-day extension
The IRS granted a foreign business entity an extension of time to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to be treated as a partnership but…
PLR 1046002: late duplicate accounting-method form is treated as timely filed
The IRS granted a taxpayer an extension of time to file the duplicate copy of Form 3115, Application for Change in Accounting Method. The taxpayer had timely filed the original form with its federal…
PLR 1046001: grain cooperative payments qualify as per-unit retain allocations for section 199
The IRS ruled that a grain cooperative's cash payments to members and other participating patrons for grain marketed through the cooperative are per-unit retain allocations paid in money. The…
Determination 1045034: final adverse determination denies exemption to an angel investor network
The IRS finalized its denial of federal tax exemption to an organization that operated an angel investor network. The organization connected accredited investors with early-stage businesses, offered…
Determination 1045033: scholarship grant program for ice skaters receives advance approval
The IRS approved a private foundation's grant-making program for scholarships to former amateur and professional ice skaters who want to pursue college education. The program uses an independent…
Determination 1045032: scholarship and historical grant programs receive advance approval
The IRS approved a private foundation's proposed scholarship and grant-making programs. The scholarship program would support international students attending a university, subject to academic,…
Determination 1045031: insurer's exemption under section 501(c)(15) is revoked
The IRS revoked a property-and-casualty insurer's exemption under section 501(c)(15), effective from a redacted date. The examination concluded that the insurer's gross receipts exceeded the…
Determination 1045030: private foundation exemption is revoked for missing records and filings
The IRS revoked a private foundation's tax-exempt status under section 501(c)(3), effective from a redacted date. The examination found that the organization repeatedly failed to file Form 990-PF…
Determination 1045029: private foundation exemption is revoked for missing records and filings
The IRS revoked a private foundation's exemption under section 501(c)(3), effective from a redacted date. The organization did not provide requested records or respond to repeated requests for…
Determination 1045028: private foundation exemption is revoked for missing records and filings
The IRS revoked a private foundation's exemption under section 501(c)(3), effective July 1 of a redacted year. The organization failed to provide documents showing that it operated exclusively for…
Determination 1045027: nonprofit opera organization loses exemption after inactivity
The IRS revoked an organization's section 501(c)(3) exemption after finding that it had not conducted activities in the relevant years. The organization had planned opera-related educational and…
Determination 1045026: organization loses exemption after failing to establish continued qualification
The IRS revoked the organization's section 501(c)(3) exemption effective January 1 of a redacted year. The organization did not establish that it operated exclusively for an exempt purpose, serve a…
Determination 1045025: organization loses exemption after failing to establish continued qualification
The IRS revoked the organization's section 501(c)(3) exemption effective January 1 of a redacted year. The organization did not provide records or respond to repeated requests needed to determine…
Other 1045024: IRS revokes an organization's section 501(c)(3) tax-exempt status
The IRS revoked an organization's section 501(c)(3) tax-exempt status. The document says the organization had ceased operations, did not file required annual Form 990 returns, and did not provide…
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.