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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Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible 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…
Trust granted more time to elect treatment of a charitable contribution
The IRS granted a trust 60 days to make an election under section 642(c)(1) to treat a charitable contribution as paid in an earlier tax year. The trust made the contribution after that year ended,…
Entity granted more time to elect disregarded-entity status
The IRS granted an entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes, effective on an earlier specified date. The entity was eligible to…
Entity granted more time to elect disregarded-entity status
The IRS granted an entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes, effective on an earlier specified date. The entity was eligible to…
Estate's wrongful-death recovery excluded from gross income
The IRS ruled that a personal representative's estate could exclude a payment received under a legislative settlement for the wrongful death of the taxpayer's relative. The payment was for…
Cooperative's grain payments treated as per-unit retain allocations
The IRS ruled that an agricultural cooperative's cash payments to members for grain marketed by the cooperative were per-unit retain allocations paid in money. The cooperative calculated those…
Foreign entity granted more time to elect disregarded-entity status
The IRS granted a foreign entity 60 more days to file Form 8832 and elect disregarded-entity status for federal tax purposes. The entity was eligible to make the classification election and intended…
Foreign entity granted more time to elect disregarded-entity status
The IRS granted a foreign entity 60 more days to file Form 8832 and elect disregarded-entity status for federal tax purposes. The entity was eligible to make the classification election and intended…
Organization treated as an integral agency of a church
The IRS ruled that an organization providing residential care for orphan children was an integral agency of a church. The organization was founded by church leaders, required its trustees and…
Estate granted more time for GST allocation and reverse QTIP election
The IRS granted an estate 60 more days to allocate the decedent's generation-skipping transfer tax exemption to two trusts and to make a reverse QTIP election for the exempt marital trust. The…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Trust division approved without adverse tax consequences
The IRS approved a proposed division of an exempt generation-skipping transfer tax trust into four separate trusts for different family lines. The IRS ruled that the division, non-pro rata…
Private foundation exemption revoked for private benefit and self-dealing
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The examination found that foundation assets benefited trustees and a related company…
LLC denied exemption for organizational and commercial-operation failures
The IRS denied an LLC's request for exemption under IRC § 501(c)(3). The organization was not organized exclusively for an exempt purpose because its individual shareholders controlled the LLC and…
Welfare-benefit fund contributions approved for deduction under stated limits
The IRS ruled that a trust funding retiree medical benefits was maintained under a collective bargaining agreement. It also ruled that a company's contribution of membership interests to the trust…
IRA rollover deadline waived after adviser error
The IRS waived the 60-day deadline for an IRA rollover. The taxpayer had received a total distribution, kept the uncashed check in a safe deposit box while away caring for a family member, and…
Extension granted to recharacterize a Roth IRA conversion
The IRS granted a taxpayer 60 additional days to recharacterize a Roth IRA conversion as a contribution to a traditional IRA. An examination later increased the taxpayers' modified adjusted gross…
IRA rollover deadline waived after taxpayer's incapacity
The IRS waived the 60-day IRA rollover deadline for an incapacitated taxpayer. The taxpayer had received a distribution, placed most of it in a checking account, and later became subject to a…
IRA rollover deadline waived after investment fraud delayed repayment
The IRS waived the 60-day rollover deadline for a later IRA distribution after an organization allegedly delayed returning the taxpayer's investment and was accused of operating a Ponzi scheme. The…
VEBA may provide benefits to dependent domestic partners and limited benefits to non-dependent partners
The IRS ruled that a tax-exempt VEBA could provide permissible health and insurance benefits to domestic partners who qualified as dependents under the tax rules. The VEBA could also provide…
Endowment unit contracts with related charitable remainder trusts do not create unrelated business income
The IRS ruled that a publicly supported charitable organization could issue contract units in its pooled endowment fund to charitable remainder trusts for which it or a related university was the…
CCA 1022021: Only the individual appraiser may sign Form 8283 and the appraisal
Chief Counsel Advice addresses who may sign Part III of Form 8283 and the corresponding appraisal. It concludes that the individual who completed the appraisal must sign both documents, rather than…
CCA 1022020: Each employer remains a separate taxpayer for centralized refund communications
Chief Counsel Advice states that each employer is a separate taxpayer for purposes of a refund claim. One person can centralize communications for multiple employers only if the person has a power…
CCA 1022019: Telephone Excise Tax Refunds are not reportable to the Joint Committee on Taxation
Chief Counsel Advice addresses a Joint Committee question concerning a Telephone Excise Tax Refund, abbreviated in the email subject as TETR. It states that the refund concerns an excise tax and is…
CCA 1022018: The applicable consolidated-return citation is Treas. Reg. § 1.1502-77
Chief Counsel Advice corrects the regulation citation for the years at issue in a consolidated-return matter involving a parent acting for subsidiaries. It states that the correct citation is Treas.…
CCA 1022017: The parent may sign for the entire consolidated group
Chief Counsel Advice states that the parent may sign for the entire consolidated group in the matter described in the email. The advice cites Treas. Reg. § 1.1502-77A and includes redacted details…
CCA 1022016: An estate may not need to file a federal estate tax return
Chief Counsel Advice states that not all estates must file federal tax returns and refers to IRC §§ 6018 and 2010(c). It also addresses an executor who must account for estate taxes paid to a…
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.