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 1027007: Single-employer welfare plans were not substantially similar to a listed trust transaction
The IRS ruled that a taxpayer's single-employer welfare benefit plans were not the same as, or substantially similar to, the listed transaction described in Notice 95-34. The plans used separate…
PLR 1027006: Late S corporation election treated as timely for reasonable cause
The IRS ruled that a corporation had reasonable cause for failing to timely file its Form 2553 to elect S corporation treatment. The corporation intended the election to be effective on the redacted…
PLR 1027005: Spouses granted more time to allocate GST exemptions to trust transfers
The IRS granted spouses an extension of time to allocate their generation-skipping transfer tax exemptions to lifetime transfers made to an irrevocable trust. The spouses had reported the transfers…
PLR 1027004: Renewable-energy developer granted more time to elect IDC amortization
The IRS granted a renewable-energy developer an extension of time to elect under section 59(e) to amortize intangible drilling and development costs over 60 months. The developer had delayed filing…
PLR 1027003: Marine transportation income qualified as publicly traded partnership income
The IRS ruled that income earned by a publicly traded limited partnership from transporting crude oil, refined petroleum products, ethanol, biodiesel, and other qualifying products was qualifying…
PLR 1027002: Partnership granted relief for late fiscal-year election
The IRS granted a partnership an extension of time to file Form 8716 and elect a tax year ending September 30. The partnership had relied on a qualified tax professional, but its form was filed late…
PLR 1027001: Inadvertent S corporation termination from a nonresident-alien shareholder
The IRS ruled that a corporation's S corporation election terminated when it issued stock to a nonresident alien, who was an ineligible S corporation shareholder. The corporation promptly redeemed…
PLR 1026043: IRS waived the 60-day rollover deadline after a bank merger error
The IRS waived the 60-day rollover requirement for a surviving spouse who received a distribution from an IRA and intended to roll most of it into another IRA. A bank merger and changes in the…
PLR 1026042: IRS waived the 60-day rollover deadline after a family death
The IRS waived the 60-day rollover requirement for an individual who moved funds from an IRA to a non-IRA account and then missed the rollover deadline after learning that a family member had died…
PLR 1026041: IRS granted more time to recharacterize an ineligible Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a Roth IRA conversion as a contribution to a traditional IRA. The taxpayer and spouse had relied on investment losses that were later challenged…
PLR 1026040: IRS waived the 60-day rollover deadline after a clerical deposit error
The IRS waived the 60-day rollover requirement for a taxpayer whose distribution from a tax-sheltered annuity was mistakenly deposited into a Roth IRA instead of the traditional IRA the taxpayer had…
PLR 1026039: IRS waived the 60-day rollover deadline after medical hardship
The IRS waived the 60-day rollover requirement for married taxpayers who missed the deadline after receiving distributions from two individual retirement annuities. The taxpayers were caring for a…
PLR 1026038: IRS waived the 60-day rollover deadline after medical conditions caused delay
The IRS waived the 60-day rollover requirement for a taxpayer who moved IRA funds to non-IRA accounts while seeking a better investment return and then missed the deadline. The taxpayer had mental…
Determination 1026037: IRS approved a private foundation’s scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to high school graduates born in a particular state. The foundation planned to award nine to thirteen scholarships each…
CCA 1026036: No assessment suspension without a partnership withholding-tax return
Chief Counsel advised that if a partnership did not file a withholding-tax return, there would be no statute of limitations to suspend under section 6503. The Service could therefore wait until the…
CCA 1026035: Collection Due Process does not automatically add 90 days to every case
Chief Counsel advised that the statute does not automatically add 90 days to every Collection Due Process case. The 90-day protection applies when the CDP hearing request is made with fewer than 90…
CCA 1026034: Partnership need not receive an FPAA when it is not a TEFRA party
Chief Counsel advised that a second power of attorney could give the designated person authority to act for the partnership. The advice also stated that the partnership was not a party to the TEFRA…
CCA 1026033: Injured-spouse claims should receive the required disallowance notice
Chief Counsel advised that the IRS need not amend its Internal Revenue Manual because the manual already required issuing a Notice of Claim Disallowance in the injured-spouse case under review. The…
PLR 1026032: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification but had failed to…
PLR 1026031: Late S corporation election treated as timely for reasonable cause
The IRS ruled that a corporation had reasonable cause for failing to timely file Form 2553 to elect S corporation treatment. The corporation intended the election to be effective on the redacted…
PLR 1026030: Late S corporation election treated as timely for reasonable cause
The IRS ruled that a corporation had reasonable cause for failing to timely file Form 2553 to elect S corporation treatment. The corporation intended the election to be effective on the redacted…
PLR 1026029: IRS treated a late S corporation election as timely after finding reasonable cause
The IRS granted relief to a corporation that intended to elect S corporation status but filed Form 2553 late. The corporation and its sole shareholder had reported their income consistently with the…
PLR 1026028: IRS treated a late S corporation election as timely after finding reasonable cause
The IRS granted relief to a corporation that intended to elect S corporation status but did not timely file Form 2553. The IRS found reasonable cause for the late election and treated it as timely…
PLR 1026027: IRS approved proposed sales of remainder interests without changing trust tax treatment
The IRS considered a proposed judicial construction of a spendthrift clause and proposed sales of remainder interests in an old family trust. It concluded that the construction and sales would not…
PLR 1026026: IRS approved proposed sales of remainder interests without changing trust tax treatment
The IRS considered a proposed judicial construction of a spendthrift clause and proposed sales of remainder interests in an old family trust. It concluded that the construction and sales would not…
PLR 1026025: IRS approved proposed sales of remainder interests without changing trust tax treatment
The IRS considered a proposed judicial construction of a spendthrift clause and proposed sales of remainder interests in an old family trust. It concluded that the construction and sales would not…
PLR 1026024: IRS approved proposed sales of remainder interests without changing trust tax treatment
The IRS considered a proposed judicial construction of a spendthrift clause and proposed sales of remainder interests in an old family trust. It concluded that the construction and sales would not…
PLR 1026023: IRS approved fee allocations for RIC share classes under the dividends-paid deduction rules
The IRS ruled for two groups of registered investment company funds that issued multiple share classes with different fees and service arrangements. The funds allocated certain transfer-agency and…
PLR 1026022: IRS treated a late S corporation election as timely after finding reasonable cause
The IRS granted relief to a corporation that intended to elect S corporation status but did not timely file Form 2553. The IRS found reasonable cause for the late election and treated it as timely…
PLR 1026021: IRS granted more time to allocate GST exemption to earlier trust transfers
The IRS granted a 60-day extension to allocate a decedent's available generation-skipping transfer tax exemption to transfers made to a trust in Years 1 through 6. The taxpayer's accountant had…
PLR 1026020: IRS granted more time to allocate GST exemption to earlier trust transfers
The IRS granted a 60-day extension to allocate a decedent's available generation-skipping transfer tax exemption to transfers made to a trust in Years 1 through 6. The taxpayer's accountant had…
PLR 1026019: IRS granted more time to allocate GST exemption to five trusts
The IRS granted the husband and wife a 60-day extension to allocate their available generation-skipping transfer tax exemptions to transfers made to five trusts. Their tax advisers had prepared…
PLR 1026018: IRS approved division of a trust into separate subtrusts
The IRS approved a proposed division of an existing trust into separate subtrusts for the descendants of a son and a daughter. The division would use different assets for each subtrust, while…
PLR 1026017: Subpart F income from wholly owned CFC subsidiaries qualifies as RIC income
The IRS ruled for a group of regulated investment companies that planned to invest in wholly owned foreign subsidiaries. The subsidiaries were expected to earn Subpart F income from investments, and…
PLR 1026016: IRS granted relief for an inadvertently late S corporation election
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The shareholders intended the election to take effect when the corporation was formed,…
PLR 1026015: IRS granted more time to elect partnership classification
The IRS granted a foreign business entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to be treated as a partnership…
PLR 1026014: IRS approved proposed sales of trust remainder interests
The IRS approved a proposed court construction that would allow several beneficiaries to sell remainder interests in an irrevocable trust. The ruling concluded that the construction and sales would…
PLR 1026013: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026012: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026011: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026010: IRS approved corporate reorganizations and asset contributions
The IRS approved the federal tax treatment of several steps intended to simplify a corporate group's structure and consolidate business activities. The steps included contributions of assets to…
PLR 1026009: IRS granted relief for an inadvertently late S corporation election
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The shareholders intended the election to take effect on the requested date, but the…
PLR 1026008: IRS kept prior transaction rulings in force after proposed revisions
The IRS issued a supplemental ruling on a previously approved corporate transaction involving the planned sale of stock in a new corporation and an initial public offering. The taxpayer revised…
PLR 1026007: IRS approved a divisive reorganization separating two businesses
The IRS approved a proposed split-off in which an S corporation would transfer one of its businesses to a newly formed corporation and distribute that corporation's stock to a group of shareholders…
PLR 1026006: IRS upheld an S corporation election after a void stock transfer
The IRS concluded that a corporation's S corporation election did not terminate when a shareholder attempted to transfer stock to an ineligible shareholder. A court had determined that the transfer…
PLR 1026005: IRS treated a reformed trust as a valid charitable remainder unitrust
The IRS treated a trust as a valid charitable remainder unitrust from its creation date after a state court retroactively corrected a scrivener's error in the trust's unitrust percentage. The…
PLR 1026004: IRS granted relief for a late S corporation election
The IRS found reasonable cause for a corporation's failure to timely file its S corporation election. It allowed the corporation to make the election effective as of its intended incorporation date,…
PLR 1026003: IRS granted relief for a late S corporation election
The IRS found reasonable cause for a corporation's failure to timely file its S corporation election. It allowed the corporation to make the election effective as of its intended incorporation date,…
PLR 1026002: IRS granted late-election relief for rental real estate activities
The IRS granted a married couple an additional 60 days to elect to treat all of their rental real estate interests as one rental real estate activity. The taxpayers were eligible to make the…
PLR 1026001: IRS granted relief for an inadvertent late S corporation election
The IRS granted a corporation relief after its intended S corporation election was inadvertently not filed. It concluded that the corporation had reasonable cause and would be treated as an S…
PLR 1025089: IRS waived the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for an individual who received a distribution from an IRA but had the funds deposited into a non-IRA account because of a financial institution…
IRS approved a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a pension plan's unfunded liabilities as of April 1, 2009. The extension applied to eligible amortization charge bases…
PLR 1025087: IRS approved a five-year extension for amortizing a pension plan's unfunded liabilities
The IRS approved a request for a five-year automatic extension to amortize a pension plan's unfunded liabilities as of February 1, 2009. The extension applied to eligible amortization charge bases…
PLR 1025086: IRS approved a five-year extension for amortizing a pension plan's unfunded 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 applied to eligible amortization charge bases…
PLR 1025085: IRS waived the 60-day IRA rollover requirement after a medical delay
The IRS waived the 60-day deadline for a taxpayer who withdrew money from an IRA and deposited it into a non-IRA savings account while intending to complete a rollover. The taxpayer said a medical…
PLR 1025084: IRS waived the 60-day IRA rollover requirement after medical and family hardships
The IRS waived the 60-day deadline for a taxpayer who withdrew money from an IRA but did not complete a rollover while dealing with a worsening medical condition and a family emergency. Part of the…
Determination 1025083: IRS revoked an art gallery organization's section 501(c)(3) exemption
The IRS revoked an art gallery organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization displayed and sold local artists' work, and the IRS concluded…
Determination 1025082: IRS proposed revoking a social club's section 501(c)(7) exemption
The IRS proposed revoking a recreation organization's exemption under IRC § 501(c)(7). The organization received 57 percent and 59 percent of its income from sources outside its membership in two…
Determination 1025081: IRS revoked a down-payment-assistance organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization operated a down-payment-assistance program for home buyers, but it did not…
Determination 1025080: IRS revoked a down-payment-assistance organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization provided down payment assistance to home buyers, but it did not screen…
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.