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 201038011: IRS granted more time to file an election relinquishing a consolidated loss carryback
A corporate group failed to timely file an election to relinquish the carryback period for a consolidated net operating loss. The taxpayer said it relied on a qualified tax professional and…
PLR 201038010: IRS granted relief for a late S corporation election
A company intended to elect S corporation status for a specified effective date, but it did not timely file Form 2553. The IRS concluded that the company had reasonable cause for the late election.…
PLR 201038009: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted a 120-day extension to make the election…
PLR 201038008: IRS treated foreign-law segregated accounts as meeting the variable-contract rule
A foreign insurance company that elected to be taxed as a domestic corporation planned to issue variable life insurance and annuity contracts backed by segregated asset accounts. The company asked…
PLR 201038007: IRS granted more time to file a duplicate Form 3115
A taxpayer timely filed an original Form 3115 to change its accounting method for internally developed computer software but inadvertently failed to file the required duplicate with the IRS national…
PLR 201038006: IRS addressed trust income ownership and estate inclusion of a withdrawal power
A taxpayer was both trustee and beneficiary of an irrevocable trust divided into two subtrusts. The taxpayer could direct distributions of income from one subtrust during its first specified years…
PLR 201038005: IRS addressed trust income ownership and estate inclusion of a withdrawal power
A taxpayer was both trustee and beneficiary of an irrevocable trust divided into two subtrusts. The taxpayer could direct distributions of income from one subtrust during its first specified years…
PLR 201038004: IRS addressed trust income ownership and estate inclusion of a withdrawal power
A taxpayer was both trustee and beneficiary of an irrevocable trust divided into two subtrusts. The taxpayer could direct distributions of income from one subtrust during its first specified years…
PLR 201038003: IRS granted late-election relief for disregarded-entity status
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted an extension of 120 days from the ruling date to make…
PLR 201038002: IRS granted late-election relief for partnership status
A foreign entity intended to be treated as a partnership for federal tax purposes but failed to timely file Form 8832. The IRS granted an extension of 120 days from the ruling date to make the…
PLR 201038001: IRS disregarded an ESOP valuation rule in testing S corporation stock classes
An S corporation had an employee stock ownership plan that acquired the company's stock in two purchases, with the second purchase financed by a loan. A plan provision protected the value of the…
Determination 201037039: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's recognition as exempt under IRC § 501(c)(3), effective January 1, 2004. The organization was structured as a trust and claimed…
PLR 201037038: IRS declined a waiver of the 60-day IRA rollover requirement
A taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another retirement account. The taxpayer said a bank deposited the distributed amount into a non-IRA…
Determination 201037037: IRS denied exemption to a pharmaceutical research organization
The IRS finalized a proposed denial of exemption for a nonprofit clinical research organization. The organization conducted pharmaceutical-sponsored studies involving hepatitis B and hepatic…
Determination 201037036: IRS proposed revocation of a veterans organization's exemption
The IRS examined a veterans organization that operated a bar and related entertainment activities while claiming exemption under IRC § 501(c)(19). The report questions whether the organization…
Determination 201037035: IRS revoked a veterans organization's exemption
The IRS revoked an existing exemption under IRC § 501(c)(19), effective January 1 of a redacted year. The examination concerned a veterans organization that operated a bar and related entertainment…
Determination 201037034: IRS revoked a dormant section 501(c)(4) organization's exemption
The IRS issued a final adverse determination for a subordinate organization covered by a section 501(c)(4) group exemption. The organization had ceased operations, had no financial resources or…
Determination 201037033: IRS revoked a section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective September 1 of a redacted year. The organization claimed to assist poor and needy…
Determination 201037032: IRS revoked a defunct section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective January 1 of a redacted year. The organization had gone out of business, received no…
Determination 201037031: IRS revoked a section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective August 1 of a redacted year. The organization failed to produce documents and respond to…
Determination 201037030: IRS revoked an animal-rescue organization's exemption
The IRS revoked a section 501(c)(3) animal-rescue organization's exemption effective January 1 of a redacted year. The organization said its purpose was to rescue abandoned horses, provide medical…
Determination 201037029: IRS revoked a youth dance organization's exemption
The IRS revoked a section 501(c)(3) youth dance organization's exemption effective January 1 of a redacted year. The organization conducted fundraising events through which parents of students at a…
CCA 201037028: Counsel advised excluding intercompany dividends from personal-holding-company calculations
Chief Counsel advised that a parent corporation could exclude intercompany dividends received from a subsidiary that was not a personal holding company when calculating adjusted ordinary gross…
CCA 201037027: Counsel advised on backup withholding after missing Form W-9 certifications
Chief Counsel advised that a payor may remain liable for backup withholding when it failed to obtain required Form W-9 certifications, even after the three-year retention period for those forms has…
PLR 201037026: IRS approved tax treatment for a multi-step spin-off and reorganization plan
The IRS ruled on a proposed series of contributions, distributions, mergers, and reorganizations involving four distributing corporations, controlled corporations, and numerous domestic and foreign…
PLR 201037025: IRS approved nuclear decommissioning-fund schedules
The IRS approved a revised schedule of ruling amounts and an initial schedule of deduction amounts for a taxpayer's interest in a nuclear power plant. The taxpayer sought the schedules under IRC §…
PLR 201037024: IRS ruled on stock repurchases affecting section 355 spin-off testing
The IRS supplemented an earlier ruling on completed and proposed section 355 distributions by a publicly traded corporation. The supplemental ruling addresses how the corporation's open-market…
PLR 201037023: IRS granted relief for a late S corporation election
The IRS granted relief to a company that failed to timely file Form 2553 to elect S corporation status. The company represented that it had consistently reported its tax matters in accordance with…
PLR 201037022: IRS granted more time for a disregarded-entity election
The IRS granted a 120-day extension for a foreign single-member limited liability company to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The company’s parent had…
PLR 201037021: IRS granted relief for a late foreign-insurance-company election
The IRS granted a foreign insurance company a 60-day extension to make an election under IRC § 953(d) to be treated as a domestic corporation for U.S. tax purposes. The company intended to make the…
PLR 201037020: IRS approved tax treatment for a corporate reorganization
The IRS ruled on a completed transaction in which a parent corporation combined the operations of two subsidiaries. One subsidiary transferred substantially all of its operating assets to the other…
PLR 201037019: IRS approved tax treatment for a corporate reorganization
The IRS ruled on a completed transaction in which a parent corporation combined the operations of two subsidiaries. One subsidiary transferred substantially all of its operating assets to the other…
PLR 201037018: IRS granted late-election relief to a foreign insurer
The IRS granted a foreign property-and-casualty insurance company 60-day extensions to make elections under IRC § 953(d) to be treated as a domestic corporation and under § 831(b) to use the…
PLR 201037017: IRS approved changes to inventory-cost allocation methods
The IRS granted a subsidiary consent to change its method for identifying and allocating inventory costs under IRC § 263A after the subsidiary merged into another company. The approved methods cover…
PLR 201037016: IRS approved nuclear decommissioning-fund schedules
The IRS approved a revised schedule of ruling amounts and an initial schedule of deduction amounts for a taxpayer's interest in a nuclear power plant. The taxpayer sought the schedules under IRC §…
PLR 201037015: IRS granted relief for a late S corporation election
The IRS granted relief to a company whose Form 2553 election to be treated as an S corporation was not filed. The company represented that its shareholders intended S corporation treatment from a…
PLR 201037014: IRS treated CFC subpart F income as qualifying RIC income
The IRS ruled that subpart F income from two wholly owned controlled foreign corporations would be qualifying income for their parent regulated investment companies under IRC § 851(b)(2). Each fund…
PLR 201037013: IRS granted more time for a section 338(h)(10) election
The IRS granted Purchaser and Sellers an extension of time to file a joint section 338(h)(10) election for Purchaser's acquisition of an S corporation. The election was not filed by the due date,…
PLR 201037012: IRS approved qualifying-income treatment for commodity-linked investments
The IRS ruled that income and gain from four commodity-linked notes would be qualifying income for two regulated investment companies under IRC § 851(b)(2). The notes used total-return and…
PLR 201037011: IRS granted late disregarded-entity election relief to three foreign entities
The IRS granted three related foreign entities 120-day extensions to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities represented that they had…
PLR 201037010: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it had been eligible for that…
PLR 201037009: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it had been eligible for that…
PLR 201037008: IRS granted late partnership elections to three foreign entities
The IRS granted three related foreign entities 120-day extensions to file Form 8832 elections to be treated as partnerships for federal tax purposes. The entities represented that they were eligible…
PLR 201037007: IRS granted extra time for a corporate classification election
The IRS granted a limited liability company a 60-day extension to file Form 8832 and elect to be treated as an association taxable as a corporation. The company had failed to make the election on…
PLR 201037006: Sale of renewable energy certificates will not create private business use
The IRS ruled that an issuer's planned sale of renewable energy certificates from a bond-financed wind facility would not create private business use of the bonds. The certificates would represent…
PLR 201037005: Data-center properties and tenant services qualify under REIT rules
The IRS ruled that a REIT's data-center properties, including their specialized structural components, qualified as real estate assets. The properties' electrical, HVAC, humidification, fire…
PLR 201037004: IRS restored an S corporation election after an impermissible shareholder acquisition
The IRS ruled that a corporation's S election terminated when a C corporation acquired its stock and became an impermissible shareholder. The IRS also found that the termination was inadvertent…
PLR 201037003: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it was eligible for that…
PLR 201037002: IRS granted late GST exemption allocation relief
The IRS granted an executor a 120-day extension to allocate the decedent's generation-skipping transfer tax exemption to a trust. The executor's tax professional timely filed the estate tax return…
PLR 201037001: IRS restored an S corporation election after trust shareholder changes
The IRS ruled that an S corporation election terminated when two trusts holding the corporation's shares were not eligible shareholders. The IRS found the termination inadvertent because the…
Determination 201036031: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective February 13, 2002. It found that the organization was not operated exclusively for…
Determination 201036030: IRS revoked an organization's section 501(c)(3) exemption for private benefit
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective January 1, 2006. It found that a substantial amount of the organization's assets…
PLR 201036029: IRS waived the 60-day IRA rollover deadline after a taxpayer's mental impairment
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer intended to transfer the funds within the same IRA but, because of diminished mental…
PLR 201036028: IRS approved a governmental excess benefit arrangement under section 415(m)
The IRS ruled that an excess benefit plan maintained by a state instrumentality qualified as a governmental excess benefit arrangement under IRC § 415(m). The plan would pay defined benefit plan…
PLR 201036027: IRS approved a judicial-system excess benefit arrangement under section 415(m)
The IRS ruled that an excess benefit plan for state court personnel qualified as a governmental excess benefit arrangement under IRC § 415(m). The plan would provide benefits limited by the…
PLR 201036026: IRS waived the 60-day IRA rollover deadline after a spouse's death and mental decline
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer had intended to move the funds to a new financial institution but deposited them into a…
Determination 201036025: IRS denied an organization's exemption and supporting-organization application
The IRS finalized its adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3) after it failed to protest a proposed denial. The organization sought treatment…
Determination 201036024: IRS denied a private school's section 501(c)(3) application over racial discrimination
The IRS finalized its adverse determination that a private school did not qualify for exemption under IRC § 501(c)(3), after the school failed to protest a proposed denial. The IRS found that the…
CCA 201036023: Assessment extension for partnership items also covers affected items
Chief Counsel advice addressed whether an agreement extending the assessment period for partnership-level items also covered gain from the sale of a partnership interest. The advice states that…
CCA 201036022: IRS advice confirmed that the listed return was sufficient
Chief Counsel advice concluded that the return identified by the taxpayer was sufficient, citing Internal Revenue Manual section 25.6.22.5.4. The advice appears to address whether the taxpayer's…
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.