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 201026041: 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 201026040: 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 201026039: 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 201026038: 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 201026037: 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 201026036: 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 201026035: 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 201026034: 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 201026033: 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 201026032: 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 201026031: 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 201026030: 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 201026029: 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 201026028: 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 201026027: 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 201026026: 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 201026025: 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 201026024: 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 201026023: 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 201026022: 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 201026021: 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 201026020: 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 201026019: 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 201026018: 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 201026017: 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 201026016: 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 201026015: 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 201026014: 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 201026013: 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 201026012: 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 201026011: 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 201026010: 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 201026009: 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 201026008: 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 201026007: 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 201026006: 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 201026005: 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 201026004: 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 201026003: 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 201026002: 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 201026001: 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 201025089: 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 201025087: 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 201025086: 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 201025085: 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 201025084: 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 201025083: 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 201025082: 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 201025081: 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 201025080: 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…
Determination 201025079: IRS denied exemption to an online bartering marketplace
The IRS denied an organization's application for recognition under IRC § 501(c)(3). The organization proposed an online marketplace where registered users could exchange goods and services, with the…
Determination 201025078: IRS denied exemption to a wine-making club operated as a commercial business
The IRS denied exemption under IRC § 501(c)(7) to a proposed wine-making club. The organization advertised wine-making services and products to the public, treated customers as members without…
Determination 201025077: IRS denied exemption to an insurer that lacked sufficient risk distribution
The IRS denied exemption under IRC § 501(c)(15) to an insurance company that primarily insured a related corporation. The determination found that the organization had too few insureds and too much…
IRS advised on signing Form 872-P for a corporate tax matters partner
The IRS advised that only the general partner could serve as the tax matters partner under section 6231(a)(7). It further advised that the corporate general partner should sign Form 872-P through an…
IRS advised on extending the statute for converted items
The IRS advised that the preferred form for extending the statute of limitations on converted items was the new Form 872, which specifically references converted items. It also noted that section…
IRS advised on at-risk and outside-basis limits for partnership losses
The IRS advised that an at-risk limitation under section 465 is determined at the partner’s return level, after taking partnership items into account unless they are adjusted in a TEFRA partnership…
IRS explained disclosure rules for partnership returns and audits
The IRS explained that a partner’s request for a complete return, including all Schedule K-1 forms, for reasons unrelated to tax administration is governed by section 6103(e). It stated that…
IRS transfer-pricing slides address intangible buy-ins and cost-sharing arrangements
This CCA contains presentation slides about transfer pricing for offshore transfers of intangible value and cost-sharing arrangements. The slides discuss buy-in or platform contribution transaction…
IRS advised on disclosure of tax information to local law enforcement
The IRS advised that IRC § 6103(i) does not provide a mechanism for disclosing tax information to local law-enforcement officials. It noted that those officials might instead obtain some or all of…
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.