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 1021004: IRS approved dividing an exempt trust into four separate family-line trusts
The IRS approved a plan to divide an older generation-skipping transfer tax-exempt trust into four separate trusts, one for each family line. The division would allocate assets on a non-pro-rata…
PLR 1021003: IRS approved dividing an exempt trust into four separate family-line trusts
The IRS approved a plan to divide an older generation-skipping transfer tax-exempt trust into four separate trusts, one for each family line. The division would allocate assets on a non-pro-rata…
PLR 1021002: IRS disregarded a corporate restructuring and rescission for federal income tax purposes
A publicly traded corporation asked how the IRS would treat a completed internal restructuring, a later rescission, and a planned post-rescission restructuring involving foreign subsidiaries and…
PLR 1021001: IRS granted relief for a late Form 1128 filing
The IRS granted a taxpayer relief for filing Form 1128 late. The form requested a change from a 52-53-week taxable year ending near January 31 to a calendar year ending December 31. The IRS found…
Determination 1020034: IRS revoked an organization's tax-exempt status
The IRS issued a final adverse determination revoking an organization's exemption under section 501(c)(3), effective January 1, 2005. The letter states that the organization was not operated…
PLR 1020033: IRS waived the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from an inherited IRA. The taxpayer said that a bank employee's clerical error placed the money in a taxable…
PLR 1020032: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020031: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020030: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020029: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020028: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020027: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 1020026: IRS waived the 60-day IRA rollover deadline because of the taxpayer's medical condition
The IRS waived the 60-day deadline for rolling a distribution from one IRA into a rollover IRA. The taxpayer said that declining health, mental confusion, and memory impairment prevented timely…
PLR 1020025: IRS approved a private foundation's transfer of all assets to another foundation
The IRS approved a private foundation's plan to transfer all of its net assets to another private foundation for less than full and adequate consideration. The transfer qualified under IRC §…
PLR 1020024: IRS approved a private foundation's scholarship grant program
The IRS approved a private foundation's program to award scholarships and grants for individual study at accredited colleges and universities. The program required applicants to live in the…
PLR 1020023: IRS approved stipends for students in summer internships
The IRS approved a private foundation's program to provide selected undergraduate students with one-time stipends for summer living expenses while they participate in internships. Students with…
PLR 1020022: IRS approved five years of neighborhood-land treatment, then denied later treatment
The IRS considered a church's request to use the neighborhood-land rule for property it purchased and mortgaged for future charitable use. The church initially rented the property while developing…
Determination 1020021: IRS denied exemption to an organization conducting political and social activities
The IRS made final an adverse determination denying tax exemption under IRC § 501(c)(3) to an organization that conducted member events involving educational, political, religious, social, and…
CCA 1020020: Counsel clarified judicial review of a reportable-transaction penalty
In an internal Chief Counsel email, the sender forwarded a question to the office with jurisdiction over the regulations under IRC § 6011 concerning reportable-transaction disclosures by S…
CCA 1020019: Counsel explained the presumption for a partner signing a partnership return
In an internal Chief Counsel email concerning an allegedly invalid signing of a TEFRA partnership return, the sender quoted IRC § 6063. That provision requires a partnership return to be signed by…
CCA 1020018: Counsel summarized when supplemental unemployment benefits are wages
In an internal Chief Counsel email, the sender explained that Rev. Rul. 90-72 builds on Rev. Rul. 56-249 rather than replacing it. The analysis states that supplemental unemployment benefits may…
CCA 1020017: Counsel addressed affected-item notices in a TEFRA partnership matter
In an internal Chief Counsel email concerning a TEFRA partnership matter, the sender explained the interaction among IRC §§ 6222, 6225, and 6230. The email states that § 6222 removes the restriction…
CCA 1020016: Counsel addressed withholding for a railway union representative
In an internal Chief Counsel email, the sender addressed a railway union representative whose employer was not an employer under IRC § 3231(a), requiring the worker to pay Tier I and Tier II…
CCA 1020015: Counsel discussed assessment procedures for inconsistent partnership reporting
In an internal Chief Counsel email concerning another TEFRA question, the sender addressed indirect partners holding an interest in one partnership through another partnership. The email states that…
CCA 1020014: Counsel discussed FICA liability and worker classification rules
In an internal Chief Counsel email, the sender considered the interaction among IRC §§ 3121(b)(20), 3121(d)(1), and 3509 when an employer failed to pay FICA tax. The email states that if the failure…
CCA 1020013: Counsel addressed the treatment of carryforwards
In an internal Chief Counsel email, the sender addressed how carryforwards should generally be disallowed in a TEFRA matter. The email states that carryforwards are generally disallowed through…
CCA 1020012: Counsel discussed a tenant's defense to levy on a judgment
In an internal Chief Counsel email concerning levy execution and lien priorities, the sender stated that the tenant appeared to have a defense to levy under IRC § 6332(a) because of execution on the…
CCA 1020011: Counsel directed an inquiry to totalization agreements
In an internal Chief Counsel email about social security taxes, the sender stated that the United States has totalization agreements with the United Kingdom and Germany. The email explained that…
CCA 1020010: Counsel discussed who may sign a government employer's tax documents
In an internal Chief Counsel email concerning an individual closing-agreement case, the sender stated that the regulations under IRC § 6501(c)(4) do not specify who may sign a consent. The email…
CCA 1020009: Counsel concluded that certain gift tax is not included in a nonresident's U.S. estate
In a Chief Counsel Advice memorandum, the IRS considered whether IRC § 2035(b) applies to the U.S. estate of a nonresident noncitizen under § 2104(b). The memorandum concludes that gift tax paid on…
PLR 1020008: IRS approved a planned merger of a holding company into its subsidiary
The IRS approved the merger of a holding company into its wholly owned operating subsidiary as a tax-free reorganization under IRC § 368(a)(1)(A). The ruling also approved nonrecognition for the…
PLR 1020007: IRS allowed an S corporation to continue after an inadvertent trust-election failure
The IRS ruled that a corporation's S corporation election terminated when its stock passed to trusts whose beneficiaries had not made the required qualified subchapter S trust elections. The IRS…
PLR 1020006: IRS treated omitted subsidiaries as having joined a consolidated return
The IRS ruled that three wholly owned subsidiaries could be treated as having joined their parent's initial consolidated federal income tax return even though Forms 1122 were not timely filed. The…
PLR 1020005: IRS ruled that wrongful-death compensation was excludable from gross income
The IRS ruled that compensation received from a government department for the wrongful death of a family member was excludable from gross income under IRC § 104(a)(2). The payment arose from a…
PLR 1020004: IRS ruled that wrongful-death compensation was excludable from gross income
The IRS ruled that compensation received from a government department for the wrongful death of a family member was excludable from gross income under IRC § 104(a)(2). The payment arose from a…
PLR 1020003: IRS treated a regulated investment company's Subpart F income as qualifying income
The IRS ruled that Subpart F income from a regulated investment company's wholly owned foreign subsidiary would be qualifying income under IRC § 851(b)(2). The fund intended to qualify each year as…
PLR 1020002: IRS granted extra time to make a QTIP election
The IRS granted an executor an extension of time to make a qualified terminable interest property election under IRC § 2056(b)(7). The executor had filed the decedent's estate tax return and…
PLR 1020001: IRS approved trust reformations and automatic GST-exemption allocations
The IRS ruled that judicial reformations of two substantially identical testamentary trusts would not be treated as the exercise, release, or lapse of general powers of appointment by the trusts'…
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.