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 201024023: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024022: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024021: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024020: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024018: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024017: IRS approved merging two grandfathered trusts
The trustees proposed merging two irrevocable trusts created before September 26, 1985, including their beneficiary subtrusts. The trusts had substantially similar distribution provisions, and the…
PLR 201024016: IRS approved a series of trust mergers without new GST tax
Trustees proposed merging four trusts in stages, creating three merged trusts. Two trusts were created before September 26, 1985, while two later trusts had already been subject to…
PLR 201024015: IRS approved a series of trust mergers without new GST tax
Trustees proposed merging four trusts in stages, creating three merged trusts. Two trusts were created before September 26, 1985, while two later trusts had already been subject to…
PLR 201024014: IRS approved a series of trust mergers without new GST tax
Trustees proposed merging four trusts in stages, creating three merged trusts. Two trusts were created before September 26, 1985, while two later trusts had already been subject to…
PLR 201024013: IRS approved 40/60 accounting for a naval ship contract
A shipbuilding company asked how to account for a Navy construction contract and an earlier design and materials contract. The IRS ruled that the two contracts should not be combined, that the…
PLR 201024012: IRS approved a QPRT modification and treated a new term interest as a gift
A settlor proposed modifying and restating a qualified personal residence trust so that the settlor’s child could grant the settlor a new term interest in the residence. The IRS ruled that the…
PLR 201024011: IRS approved a state deferred compensation plan under § 457(b)
A state requested a ruling on its restated deferred compensation plan under § 457(b). The plan allowed certain deferrals from accumulated sick or vacation pay, transfers from other eligible § 457(b)…
PLR 201024010: IRS granted more time to allocate GST exemption
A grantor and spouse made transfers to an irrevocable trust but did not allocate generation-skipping transfer tax exemption on their timely filed gift tax returns. The taxpayers represented that no…
PLR 201024009: IRS granted more time to allocate GST exemption
A spouse made several transfers to an irrevocable trust but did not allocate generation-skipping transfer tax exemption on timely filed gift tax returns. The taxpayers represented that no…
PLR 201024008: IRS approved a QTIP trust division and related gifts
A surviving spouse proposed dividing and terminating a marital trust that had qualified as QTIP property for estate tax purposes. Under the court-approved arrangement, the spouse would retain…
PLR 201024007: IRS granted more time to elect disregarded-entity status
A foreign single-member entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS found that the taxpayer acted reasonably and in good…
PLR 201024006: IRS granted more time to allocate GST exemption
A grantor and spouse made transfers to two irrevocable trusts but did not allocate generation-skipping transfer tax exemption to those transfers. The taxpayers relied on an accountant who had not…
PLR 201024005: IRS treated a QRP transfer during divorce as a gift
A taxpayer had deferred gain after selling company stock to an employee stock ownership plan and purchasing qualified replacement property. During a divorce, the taxpayer proposed transferring some…
PLR 201024004: IRS treated CFC income as RIC qualifying income
A regulated investment company planned to invest through a wholly owned foreign subsidiary that would be a controlled foreign corporation. The subsidiary would invest in commodities and…
PLR 201024003: IRS treated CFC income as RIC qualifying income
A regulated investment company planned to invest through a wholly owned foreign subsidiary that would be treated as a controlled foreign corporation. The subsidiary expected to invest in commodities…
PLR 201024002: IRS recognized foreign transfer agents as financial institutions
A worldwide financial group asked whether its foreign transfer agents qualified as financial institutions under the Treasury regulations. The transfer agents maintained investor accounts, processed…
PLR 201024001: IRS recognized affiliation with a nonprofit medical corporation
A parent corporation’s subsidiary acquired the sole membership interest in a taxable nonprofit medical corporation. State law left professional medical decisions to the nonprofit’s physician board,…
IRS denied § 501(c)(3) exemption for an organization whose primary activity was gaming
The IRS issued a final adverse determination that the organization did not qualify for exemption under § 501(c)(3), effective December 31, 2007. Its primary activity was operating bingo games and…
PLR 201023073: IRS waived the 60-day IRA rollover deadline
A taxpayer received a distribution from an IRA but the financial institution deposited the funds into a non-IRA mutual fund account instead of the taxpayer’s IRA. The taxpayer said the funds had not…
PLR 201023072: IRS waived the 60-day rollover deadline after an erroneous second IRA distribution
A taxpayer received a second required minimum distribution from an IRA after a financial institution mistakenly processed an already-satisfied distribution. The taxpayer said the second transfer was…
PLR 201023071: 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 July 1, 2010. The extension applies to eligible amortization charge bases…
PLR 201023070: 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 March 1, 2009. The extension applies to eligible amortization charge bases…
PLR 201023069: 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 applies to eligible amortization charge bases…
PLR 201023068: 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 July 1, 2009. The extension applies to eligible amortization charge bases…
PLR 201023067: 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 June 1, 2009. The extension applies to eligible amortization charge bases…
PLR 201023066: IRS approved a private foundation's scholarship grant program
The IRS approved a private foundation's proposed scholarship grant-making program under IRC § 4945(g)(1). The program would provide undergraduate scholarships to students from a specified country…
Determination 201023065: IRS revoked a small property and casualty insurer's section 501(c)(15) exemption
The IRS revoked a small property and casualty insurer's exemption under IRC § 501(c)(15), effective January 1, 20XX. The examination report states that the organization did not meet the applicable…
Determination 201023064: IRS revoked an errors and omissions insurance organization's section 501(c)(15) exemption
The IRS revoked an errors and omissions insurance organization's exemption under IRC § 501(c)(15), effective January 1, 20XX. The attached examination report states that the organization did not…
Determination 201023063: IRS revoked a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective July 1, 20XX. The examination report states that nonmember receipts from food, drinks, facility use, parties, events, and…
Determination 201023062: IRS revoked a credit-counseling organization's section 501(c)(3) exemption
The IRS revoked a credit-counseling organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The examination report states that the organization had stopped conducting the…
Determination 201023061: IRS revoked a section 501(c)(3) exemption for failure to file returns and records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The final letter states that the organization failed to produce documents showing that it operated…
Determination 201023060: IRS revoked a section 501(c)(3) exemption for inactivity
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The final letter states that the organization was inactive and had conducted no operations or financial…
Determination 201023059: IRS revoked a debt-management organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization operated a debt-management program that negotiated repayment plans, answered client…
Determination 201023058: IRS denied exemption to a proposed charitable assistance organization
The IRS denied an organization's application for exemption under IRC § 501(c)(3). The organization proposed providing food, clothing, shelter, vehicles, financial assistance, and other services to…
Determination 201023057: IRS revoked exemption after dissolved organization distributed assets improperly
The IRS revoked an organization's exemption under IRC § 501(c)(3) after it dissolved and distributed part of its remaining assets to organizations that were not exempt under § 501(c)(3). The…
Spun-off corporation could deduct an assumed settlement liability but not use section 1341 treatment
Chief Counsel Advice considered whether a corporation formed in a divisive reorganization could use IRC § 1341 tax-restoration treatment for a settlement payment tied to income previously reported…
Swaption losses should be matched over the underlying swap period
Chief Counsel Advice considered the timing of losses on two interest-rate swaptions that expired worthless. The advice concluded that the loss equal to the premium paid should not be deducted…
201023054: IRS revoked an organization's section 501(c)(3) exemption over down payment assistance activities
The IRS issued a final adverse determination revoking an organization’s recognition of exemption under section 501(c)(3). The organization was formed to support affordable housing, but the report…
Returns and allowances are not subtracted under section 6501(e)(1)(A)(i)
Chief Counsel Advice considered how returns and allowances affect the six-year assessment period under IRC § 6501(e)(1)(A)(i), which applies when omitted gross income exceeds 25 percent of the…
Taxpayer granted 60 days to file the correct Form 3115
The IRS granted a taxpayer an extension of time to file the signed original of Form 3115, Application for Change in Accounting Method. The taxpayer had submitted the correct signed duplicate to the…
Taxpayer permitted to reelect the foreign earned income exclusion
The IRS permitted a taxpayer to reelect the foreign earned income exclusion under IRC § 911 for 2008 and later taxable years. The taxpayer had elected the exclusion while working in one foreign…
IRA division and distributions would not trigger generation-skipping transfer tax
The IRS ruled that dividing an inherited IRA into two accounts and making annual distributions would not cause a trust to become subject to the generation-skipping transfer tax. The trust became…
Taxpayer granted more time to elect Canadian RRSP tax deferral
The IRS granted a taxpayer an extension of time to elect treaty-based deferral of U.S. tax on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had become a U.S.…
Foreign 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 had been eligible to make the election but inadvertently…
Foreign 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 had been eligible to make the election but inadvertently…
Foreign 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 had been eligible to make the election but inadvertently…
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…
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.