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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 201029010: IRS grants late entity-classification and S corporation election relief
A limited liability company asked for more time to elect classification as an association taxable as a corporation and to file a late S corporation election. The company had intended both elections…
PLR 201029009: The IRS granted a foreign entity more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had inadvertently failed to file the…
PLR 201029008: The IRS granted a foreign entity more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had inadvertently failed to file the…
PLR 201029007: The IRS modified and supplemented a corporate reorganization ruling
The IRS supplemented an earlier private letter ruling for a corporate separation involving a distributing corporation, a controlled corporation, multiple subsidiary liquidations and mergers, and…
PLR 201029006: The IRS accepted a late Form 1128 to change the taxpayer’s accounting period
The IRS treated a taxpayer’s late Form 1128 as timely filed for a requested change from a December 31 year-end to a September 30 year-end. The taxpayer had missed the filing deadline for the short…
PLR 201029005: The IRS restored an S corporation election after an inadvertent trust-election failure
The IRS determined that a corporation’s S corporation election terminated inadvertently after three trusts received its stock and their beneficiaries failed to make the required Qualified Subchapter…
PLR 201029004: The IRS allowed a late election to combine rental real estate activities
The IRS granted married taxpayers 60 days to make a late election to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were in a real property…
PLR 201029003: The IRS approved two tuition-reduction plans as tax-free benefits
The IRS concluded that an educational organization’s two tuition-reduction plans qualified for exclusion from employees’ gross income under IRC § 117(d). Plan A covered eligible children of…
PLR 201029002: The IRS approved dividing a charitable remainder trust after divorce
The IRS approved a proposed division of a charitable remainder unitrust into two separate charitable remainder unitrusts after the divorce of the two lifetime beneficiaries. Each new trust would pay…
PLR 201029001: The IRS granted relief for a late S corporation election
The IRS found that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation’s sole shareholder intended the election to be effective on the…
PLR 201028047: The IRS waived the 60-day rollover deadline because of a medical condition
The IRS waived the 60-day rollover requirement for a taxpayer who had withdrawn funds from an IRA but did not complete the rollover on time because a medical condition impaired her ability to handle…
PLR 201028046: The IRS waived the 60-day rollover deadline after erroneous financial advice
The IRS waived the 60-day rollover requirement for a taxpayer who delayed rolling an IRA distribution over after receiving erroneous advice from a financial advisor. The taxpayer had requested…
IRS determination 201028045: The IRS approved a scholarship grant-making procedure
The IRS approved a private foundation’s procedure for awarding scholarships to children of deceased members of the United States Armed Forces or first responders. Applicants had to attend designated…
PLR 201028044: The IRS extended the period for a private foundation to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings in a publicly traded corporation. The foundation had received nearly all of its shares from a…
PLR 201028043: The IRS approved a foundation’s grant program for emerging choreographers
The IRS approved a private foundation’s program to award grants to individuals creating new dance works or completing partially created works. The foundation planned to select emerging…
IRS determination 201028042: The IRS denied exemption to a membership organization that paid member funeral benefits
The IRS denied tax-exempt status under IRC § 501(c)(7) to a membership organization that provided financial assistance, including funeral benefits, to its members and their families. The…
CCA 201028041: Chief Counsel addressed notice to partners after a tax matters partner dissolved
Chief Counsel Advice addressed whether the dissolution of a tax matters partner affected notice and election rights in a partnership proceeding. The advice asked whether a generic notice of the…
CCA 201028040: Chief Counsel allowed credit for FIRPTA withholding not remitted by the buyer
Chief Counsel Advice concluded that a nonresident alien seller could receive credit for tax withheld under FIRPTA even though the buyer did not remit the withheld amount to the IRS. The seller had…
CCA 201028039: Chief Counsel applied hedge-timing rules to a floating-to-fixed swap
Chief Counsel Advice addressed the timing of gain or loss from a floating-to-fixed interest-rate swap that hedged floating-rate debt. The advice concluded that the hedge gain or loss should be…
CCA 201028038: Chief Counsel identified the treaty article that most likely governed pension income
Chief Counsel Advice considered which article of an unnamed income tax treaty applied to pension or similar remuneration. It stated that Article 3(2) would apply the U.S. definition of “pensions and…
CCA 201028037: Chief Counsel addressed TEFRA issues after partnership dissolution
Chief Counsel Advice addressed several TEFRA partnership-proceeding questions. It concluded that a § 743(b) election was a partnership item, that a statute extension at the source partnership level…
CCA 201028036: Employer remained liable for its share of FICA taxes after settling other violations
Chief Counsel considered an employer's liability for its share of FICA taxes after the employer settled other legal violations with another federal agency. The advice states that the employer…
CCA 201028035: IRS required authorization before responding to an SS-8 representative
Chief Counsel considered whether the IRS could respond to a representative about an SS-8 request. The advice states that the representative first had to demonstrate authorization through Form 2848.…
CCA 201028034: IRS could use a paper levy to collect an existing stream of payments
Chief Counsel addressed whether the IRS could continue receiving payments under a paper levy instead of using the Federal Payment Levy Program. The advice states that a timely levy on a fixed and…
CCA 201028033: Rejected settlement form could not be signed until returned
Chief Counsel considered whether the IRS could sign a returned copy of Form 870-PT after rejecting the taxpayer's original settlement offer. The advice states that the IRS could have cosigned the…
CCA 201028032: FPAA had to be issued to the partnership entity as a partner
Chief Counsel addressed the notices required for a partnership proceeding and a possible non-filing penalty. The advice states that the IRS needed to issue a Final Partnership Administrative…
CCA 201028031: Partnership withholding liability was a partnership item
Chief Counsel addressed several questions about IRC § 1446 withholding in a partnership proceeding. The advice treats the partnership entity as the taxpayer in the circumstances presented and says…
PLR 201028030: The IRS treated merger consideration as a separate intercompany transaction
The IRS ruled on a proposed restructuring in which a parent corporation would create a new holding company for one business line by merging six subsidiaries into newly formed merger subsidiaries. In…
PLR 201028029: The IRS treated merger consideration as a separate intercompany transaction
The IRS ruled on a proposed restructuring in which a parent corporation would create a new holding company for one business line by merging six subsidiaries into newly formed merger subsidiaries. In…
PLR 201028028: The IRS granted relief for a 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 corporation showed reasonable cause for the late election and otherwise had to…
PLR 201028027: The IRS applied the U.S.-Russia treaty's 183-day condition to partnership income
The IRS ruled on the U.S. tax treatment of a Russian resident's distributive share of income from a service partnership with offices in the United States and Russia. The partner was not a U.S.…
PLR 201028026: The IRS applied the U.S.-Russia treaty's 183-day condition to partnership income
The IRS ruled on the U.S. tax treatment of a Russian resident's distributive share of income from a service partnership with offices in the United States and Russia. The partner was not a U.S.…
PLR 201028025: The IRS granted a foreign insurer more time to make two tax elections
The IRS granted a foreign insurance company 60 more days to elect domestic corporation treatment under IRC § 953(d) and to elect the alternative tax for certain small insurance companies under IRC §…
PLR 201028024: The IRS waived an inadvertent S corporation termination
The IRS ruled that a corporation's S corporation election terminated when an ineligible shareholder became a shareholder. The termination was discovered later, and steps were taken to restore the…
PLR 201028023: The IRS extended the time to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification as…
PLR 201028022: The IRS extended the time to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification as…
PLR 201028021: The IRS extended the time to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification as…
PLR 201028020: The IRS extended the time to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification as…
PLR 201028019: The IRS extended the time to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification as…
PLR 201028018: The IRS granted a consolidated group more time to elect bonus-depreciation credit treatment
The IRS granted a software company more time to elect the rules under IRC § 168(k)(4). Those rules traded certain bonus depreciation deductions for increased business-credit and…
PLR 201028017: The IRS approved a securities partnership's method for making section 704(c) allocations
The IRS approved a securities partnership's use of the full netting approach for aggregating built-in gains and losses on qualified financial assets when making reverse § 704(c) allocations. The…
PLR 201028016: The IRS approved a securities partnership's method for making section 704(c) allocations
The IRS approved a securities partnership's use of the full netting approach for aggregating built-in gains and losses on qualified financial assets when making reverse § 704(c) allocations. The…
PLR 201028015: The IRS granted more time to elect U.S. tax deferral for Canadian retirement plans
The IRS granted a U.S. resident 60 more days to elect to defer U.S. federal income taxation on income accrued in Canadian Registered Retirement Savings Plans. The taxpayer had not known that an…
PLR 201028014: The IRS granted more time to elect U.S. tax deferral for a Canadian retirement plan
The IRS granted a U.S. citizen and resident 60 more days to elect to defer U.S. federal income taxation on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had not known…
PLR 201028013: The IRS granted more time to file a foreign entity classification election
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect its federal tax classification. The entity was eligible to make the election effective on a redacted date, but the…
PLR 201028012: The IRS granted more time to file a foreign entity classification election
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect its federal tax classification. The entity was eligible to make the election effective on a redacted date, but the…
PLR 201028011: The IRS granted more time to elect association status for a foreign entity
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as an association taxable as a corporation. The entity intended the election to be effective on a…
PLR 201028010: The IRS granted a foreign eligible entity more time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity 60 more 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 effective on…
PLR 201028009: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 201028008: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 201028007: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 201028006: The IRS ruled on stock treatment for ownership-change and consolidated-group purposes
The IRS ruled on the federal tax treatment of several preferred-stock issuances by the common parent of a consolidated group. For purposes of the applicable guidance under IRC §§ 56, 382, and 383,…
PLR 201028005: The IRS granted more time to waive a consolidated net operating loss carryback
The IRS granted a consolidated group 45 more days to file an election waiving the entire carryback period for a consolidated net operating loss. The group had missed the filing deadline after…
PLR 201028004: The IRS granted late-election relief for S-corporation status
The IRS granted a corporation relief for failing to timely elect S-corporation status. The corporation had intended the election to be effective on its incorporation date and established reasonable…
PLR 201028003: The IRS granted late-election relief for S-corporation status
The IRS granted a corporation relief for failing to timely elect S-corporation status. The corporation intended the election to be effective on a specified date but did not file the proper election…
PLR 201028002: The IRS granted more time to elect corporate classification for an LLC
The IRS granted a limited liability company 60 more days to file Form 8832 and elect to be treated as an association taxable as a corporation. The LLC had converted under state law but did not…
IRS employees may disclose taxpayer information to authorized entity fiduciaries
The Office of Chief Counsel advised that IRS Customer Service Representatives may disclose a taxpayer's returns and return information to individuals authorized to bind an entity named as the…
PLR 201027061: The IRS waived the 60-day IRA rollover requirement after a bank error
The IRS waived the 60-day rollover requirement for an IRA distribution after a bank employee deposited the funds into a non-IRA account instead of the rollover IRA specified in the taxpayer's…
PLR 201027060: The IRS approved a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding four-year scholarships to students enrolled in elementary schools, subject to the foundation's stated selection and oversight rules.…
PLR 201027059: The IRS approved a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed program to award one-time scholarships to graduating seniors of a school or residents of a school district. The foundation planned to use an…
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.