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 201016019: Foreign entity receives extra time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election after a…
PLR 201016018: Foreign entity receives extra time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election after a…
PLR 201016017: Foreign entity receives extra time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election after a…
PLR 201016016: S election restored after trust shareholder problem
The IRS ruled that a corporation's S corporation election terminated when stock was transferred to a trust that no longer qualified as an eligible S corporation shareholder. The termination was…
PLR 201016015: S election restored after trust shareholder problem
The IRS ruled that a corporation's S corporation election terminated when stock was transferred to a trust that no longer qualified as an eligible S corporation shareholder. The termination was…
PLR 201016014: TRSs will not be treated as operating facilities managed by eligible independent contractors
The IRS ruled that a publicly traded real estate investment trust's taxable REIT subsidiaries would not be treated as directly or indirectly operating or managing certain facilities merely because…
PLR 201016013: Extension granted for a late qualified subchapter S subsidiary election
The IRS granted a corporation an additional 60 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The corporation intended the election to be effective on an…
PLR 201016012: Retroactive credit card issuer registration relief denied
The IRS denied a fuel seller's request to make its credit card issuer registration under IRC § 4101 retroactive to January 1, 2006. The taxpayer had been registered as an ultimate vendor and later…
PLR 201016011: Extension granted for a late foreign entity classification election
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was wholly owned by a trust and…
PLR 201016010: Late entity classification and S corporation elections approved
The IRS granted a limited liability company additional time to elect to be treated as an association taxable as a corporation and to make a late S corporation election. The LLC had one member and…
PLR 201016009: Extension granted for a late disregarded entity election
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The company was eligible to make the election but…
PLR 201016008: Extension granted for late homeowners association elections
The IRS granted a condominium management association an extension to make the elections required to be treated as a homeowners association under IRC § 528 for several taxable years. The association…
PLR 201016007: Extension granted for a late disregarded entity election
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election and…
PLR 201016006: Extension granted for a late alternate valuation election
The IRS granted an estate's personal representative an extension to make a late alternate valuation election under IRC § 2032. The estate tax return had been prepared without considering the…
PLR 201016005: Consent granted for a retroactive qualified electing fund election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer had been advised that the foreign corporation…
PLR 201016004: Consent granted for a retroactive qualified electing fund election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer had reported the foreign corporation as a…
PLR 201016003: Consent granted for a retroactive qualified electing fund election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a passive foreign investment company. The taxpayer held the investment indirectly through a trust…
PLR 201016002: Foreign derivatives exchange recognized as a qualified board or exchange
The IRS determined that a foreign derivatives exchange had rules adequate to qualify as a qualified board or exchange under IRC § 1256(g)(7)(C). The exchange was subject to its home country's…
PLR 201016001: Extension granted for a late controlled group value restoration election
The IRS granted an extension for a successor in interest to file an election to restore value under Treas. Reg. § 1.382-8(h). The election was required after an ownership change reduced the value of…
Other 201015045: Exempt status revoked because foundation assets benefited founders
The IRS revoked a foundation's recognition as a section 501(c)(3) exempt organization, effective retroactively. The foundation had been created as a supporting organization, but most of its assets…
Other 201015044: Exemption revoked for down payment assistance program that served private interests
The IRS revoked an organization's recognition as exempt under section 501(c)(3), effective April 26, 2002. The organization provided down payment assistance to homebuyers, but it did not limit the…
Other 201015043: Insurance exemption modified and revoked after voluntary taxable filing
The IRS Appeals Office modified an adverse determination and enclosed a new determination letter revoking an insurance company’s section 501(c)(15) tax exempt status for years beginning on or after…
PLR 201015042: IRS waives the 60-day rollover period after medical treatment caused an account setup error
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into a rollover IRA. The taxpayer had surgery, experienced significant medication side effects, and mistakenly opened a…
PLR 201015041: IRS waives the 60-day rollover period after a financial institution lost the distribution check
The IRS waived the 60-day deadline for a taxpayer to roll an IRA distribution into another IRA. The taxpayer instructed a financial institution to transfer the distribution into an IRA annuity, but…
PLR 201015040: IRS waives the 60-day rollover period after an unauthorized IRA distribution
The IRS waived the 60-day deadline for a taxpayer to roll over an IRA distribution. The taxpayer was hospitalized and later learned that a power of attorney had requested the surrender of the IRA…
PLR 201015039: IRS denies waiver of the 60-day IRA rollover period after an improper self-directed investment
The IRS denied a taxpayer's request to waive the 60-day deadline for rolling an IRA distribution into another IRA. The taxpayer withdrew funds to buy an interest in a privately held company after…
PLR 201015038: IRS waives the 60-day IRA rollover period after incorrect advice from a financial institution
The IRS waived the 60-day deadline for a taxpayer to roll over an IRA distribution. A financial-institution representative incorrectly told the taxpayer that she could redeposit the funds by the end…
PLR 201015037: One-time brokerage commission received by exempt organization is not UBTI
The IRS ruled that a brokerage commission received by a section 501(c)(3) health-care organization was not unrelated business taxable income. The organization’s chief executive, who was also a…
PLR 201015036: IRS approves private foundation scholarship grant procedures
The IRS approved a private foundation’s procedures for awarding college and vocational scholarships. Eligible recipients are graduating seniors from either of two local high schools who have good…
PLR 201015035: IRS approves private foundation scholarship procedures
The IRS approved a private foundation’s procedures for awarding scholarships to graduating seniors at a local high school. The program considers academic standing, citizenship, and participation in…
PLR 201015034: IRS approves employer-related scholarship grant procedures
The IRS approved a private foundation’s procedures for funding scholarships for children and other relatives of an employer’s employees. A public charity administers the program, uses independent…
PLR 201015033: IRS approves contingent set-aside while court-ordered litigation blocks distributions
The IRS approved a private foundation’s request to set aside undistributed income while litigation and a court order prevented it from making grants. The foundation had agreed to fund projects…
PLR 201015032: Newco stock qualifies for affiliated-group ownership treatment
The IRS considered a proposed transaction in which a publicly traded parent’s affiliated group would capitalize a newly formed corporation, Newco, to acquire an indirect interest in real-estate…
PLR 201015031: Newco stock qualifies for affiliated-group ownership treatment
The IRS considered a proposed transaction in which a publicly traded parent’s affiliated group would capitalize Newco to acquire an indirect interest in multiple real-estate projects through a…
TAM 201015030: Provisional insurance receivables included in subpart F income
The IRS advised that provisional indemnification receivables for incurred-but-not-reported loss reserves must be included in a foreign insurer’s subpart F insurance income and earnings and profits.…
PLR 201015029: IRS approves proposed tax-free separation of business lines
The IRS approved a proposed separation of one business line from a publicly traded corporation through a contribution of assets to a newly formed subsidiary followed by a pro rata distribution of…
PLR 201015028: IRS approves proposed stock acquisitions treated as asset acquisitions under section 338
The IRS approved a proposed divestiture in which a corporate group would transfer several domestic and foreign subsidiaries and related assets to a newly formed corporation. The new corporation…
PLR 201015027: IRS grants more time to make elections for Canadian retirement savings plans
The IRS granted an individual additional time to elect deferral of U.S. taxation on income accrued in Canadian Registered Retirement Savings Plans. The taxpayer had not made the elections under the…
PLR 201015026: IRS permits a taxpayer to revise a capital-gain investment-income election
The IRS granted an individual permission to revoke the amount of an earlier election that treated net capital gain as investment income for purposes of the investment-interest deduction. The…
PLR 201015025: IRS approves proposed modifications to two pre-1985 irrevocable trusts
The IRS approved proposed modifications to two irrevocable trusts created before September 25, 1985, for a parent and descendants. The modifications would be made under state law by agreement among…
PLR 201015024: IRS finds post-sale business activity satisfied continuity requirements
The IRS ruled that a corporation's post-sale activities using historic business assets satisfied the continuity of business enterprise requirement after an ownership change. The corporation had…
PLR 201015023: IRS permits a method for measuring ownership changes caused by stock-value fluctuations
The IRS approved a method for a corporation to factor out changes in proportionate ownership that resulted solely from fluctuations in the relative fair market values of different classes of stock.…
PLR 201015022: IRS grants late-election relief for S corporation status
The IRS granted a company relief after it failed to timely file Form 2553 to elect S corporation status. The company intended the election to be effective on a specified date and established…
PLR 201015021: IRS grants additional time to elect partnership classification
The IRS granted a foreign eligible entity additional time to elect partnership classification for federal tax purposes. The entity intended to make the election effective on a specified date, but…
PLR 201015020: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a single-member limited liability company additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The company had inadvertently…
PLR 201015019: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a single-member limited liability company additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The company had inadvertently…
PLR 201015018: IRS classifies cooperative cash advances as per-unit retain allocations
The IRS ruled for a tax-exempt agricultural cooperative on how cash advances to members should be treated for section 199 purposes. The cooperative bought and marketed members' agricultural products…
PLR 201015017: IRS finds stock agreements and options do not create a second stock class
The IRS ruled that a corporation's shareholder transfer restrictions, redemption arrangements, and two stock option plans did not cause the corporation to have more than one class of stock for S…
PLR 201015016: IRS excludes directly awarded attorneys' fees from a plaintiff's income
The IRS ruled that attorneys' fees awarded directly to two legal organizations and a law firm were not includible in a plaintiff's gross income. The plaintiff had prevailed in a non-class lawsuit,…
PLR 201015015: IRS approves replacement real estate for involuntarily converted easements
The IRS ruled that a public authority's acquisition of temporary and permanent easement rights in investment property was an involuntary conversion under section 1033. The taxpayer planned to use…
PLR 201015014: IRS grants late relief for an S corporation election
The IRS granted a corporation relief after it failed to timely file an election to be treated as an S corporation. The corporation established reasonable cause for the failure and was allowed 60…
PLR 201015013: IRS preserves S corporation status after late ESBT elections
The IRS treated a corporation as continuing to be an S corporation after its status was inadvertently terminated when stock was transferred to two trusts that had not timely filed Electing Small…
PLR 201015012: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign limited liability company additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The company was formed by a single member,…
PLR 201015011: IRS grants late relief to elect corporate classification
The IRS granted an eligible entity additional time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity intended the election to…
PLR 201015010: IRS grants late relief for a qualified subchapter S subsidiary election
The IRS granted an S corporation additional time to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent intended the election to be effective on the…
PLR 201015009: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign entity additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The entity was wholly owned by another company, intended the…
PLR 201015008: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign entity additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The entity was wholly owned by another company, intended the…
PLR 201015007: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign entity additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The entity was wholly owned by another company, intended the…
PLR 201015006: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign entity additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The entity was wholly owned by another company, intended the…
PLR 201015005: IRS grants late relief to elect disregarded-entity treatment
The IRS granted a foreign entity additional time to file Form 8832 and elect disregarded-entity classification for federal tax purposes. The entity was wholly owned by another company, intended the…
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.