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 201015004: IRS approves consolidated-return treatment after a multinational restructuring
The IRS ruled on the federal income tax consequences of a multinational restructuring intended to consolidate multiple U.S. groups into one U.S.-based group. The transaction included contributions…
PLR 201015003: IRS grants some estate-tax relief but denies late section 6166 relief
The IRS ruled on an estate's late-filed Form 706 and requested elections involving farm property. It allowed the estate to elect special-use valuation under section 2032A and to treat the farm…
PLR 201015002: IRS approves a complex corporate reorganization and spin-off
The IRS issued rulings on a proposed series of reorganizations, contributions, and a distribution of controlled-corporation stock by a multinational corporate group. The transaction included a stock…
PLR 201015001: IRS preserves S corporation status after late ESBT elections
The IRS ruled that a corporation's S corporation election was inadvertently terminated when two trusts became ineligible shareholders after failing to make timely Electing Small Business Trust…
IRS approves a five-year extension for amortizing an employee benefit plan's unfunded liabilities
The IRS approved a five-year extension for a pension plan to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of January 1, 2009, and is…
IRS approves a five-year extension for amortizing an employee benefit plan's unfunded liabilities
The IRS approved a five-year extension for a pension plan to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of January 1, 2009, and is…
IRS approves a five-year extension for amortizing an employee benefit plan's unfunded liabilities
The IRS approved a five-year extension for a pension plan to amortize unfunded liabilities. The extension applies to eligible amortization charge bases established as of January 1, 2009, and is…
IRS waives the 60-day rollover deadline after erroneous financial advice
The IRS waived the 60-day rollover requirement for an individual who received a distribution from an individual retirement annuity and placed the funds in a non-IRA account after relying on…
IRS approves an employer-related scholarship grant program
The IRS approved a private foundation's proposed scholarship program for children and grandchildren of an employer's employees. The program used an independent selection committee, objective…
IRS approves a scholarship program for children of low-income families
The IRS approved a private foundation's proposed scholarship program for children from families that demonstrate financial need and other specified criteria. Scholarships would support attendance at…
IRS updates approval of a private foundation's scholarship program
The IRS approved an update to a private foundation's advance-approved scholarship grant program. The program would award scholarships to academically qualified graduates of high schools in a…
IRS approves a scholarship program for students with financial need
The IRS approved a private foundation's proposed scholarship program for eligible students with financial need and a connection to a specified community. Scholarships could be used for tuition,…
IRS denies exemption to a mobile-homeowners association
The IRS denied tax exemption under IRC § 501(c)(3) to an association representing mobile-home owners in a small, private community. The organization sought to represent residents in dealings with…
CCA 201014067: IRS discusses FICA withholding for nonresident alien students
Chief Counsel advice discusses FICA withholding for nonresident alien students temporarily in the United States on F, J, M, or Q visas. The advice notes that wages paid to these students are…
CCA 201014066: IRS discusses contacting an LLC manager during an examination
Chief Counsel advice addresses whether a revenue agent could contact a person identified as an LLC manager during an examination. It explains that IRC § 6103 generally protects return information,…
CCA 201014065: IRS advises using the partnership's correct EIN on a consent
Chief Counsel advice addresses the employer identification number to use on a partnership consent. It recommends using the partnership's correct EIN so that the partnership involved is correctly…
CCA 201014064: IRS discusses IRA-owned LLC sale proceeds
Chief Counsel advice discusses whether an IRA owner’s receipt of proceeds from the sale of an investment held by an IRA-owned LLC could create a prohibited transaction. The advice refers to section…
CCA 201014063: IRS discusses the small-partnership TEFRA exception
Chief Counsel advice concludes that the TEFRA partnership procedures apply because the small-partnership exclusion is available only when all partners are individuals or C corporations. Based on the…
CCA 201014062: IRS discusses timing of income from partnership hot assets
Chief Counsel advice discusses when income attributable to partnership hot assets should be recognized after a sale. It states that if the sale occurred in year 1, the income should be recognized in…
CCA 201014061: IRS discusses partnership-level treatment of a partner's sale
Chief Counsel advice discusses how to determine a partner's gain when the partnership treated the partner as having sold an interest in year 1 but later issued a Schedule K-1 for a different year.…
CCA 201014060: IRS discusses affected-item notices and partnership-interest proceeds
Chief Counsel advice addresses inconsistently reported cancellation-of-debt income and the sale of a partnership interest. It states that the IRS would need to issue an affected-item notice to…
CCA 201014059: IRS discusses § 9100 relief for a § 338(h)(10) election
Chief Counsel advice concludes that a taxpayer does not qualify for an extension of time under section 9100 to make a section 338(h)(10) election when the statute of limitations was not extended or…
CCA 201014058: IRS discusses an omitted partnership item
Chief Counsel advice states that if a partner failed to include an income item, section 6222 permits the IRS to assess the inconsistently reported item. The partnership return controls the years in…
CCA 201014057: IRS discusses frivolous collection due process requests
Chief Counsel advice states that under section 6330(g), the IRS will deny a collection due process hearing request that contains only frivolous arguments if the taxpayer fails to file a proper…
CCA 201014056: IRS analyzes a façade-easement contribution
Chief Counsel advice provides legal analysis concerning a redacted taxpayer's contribution of a façade easement. It discusses the qualified conservation contribution rules under section 170,…
CCA 201014055: IRS discusses whether an SFR is required before an FPAA
Chief Counsel advice states that an IRS substitute for return is not necessary before the IRS issues an FPAA, based on confirmation from the section 6020(b) branch. The message concerns a substitute…
CCA 201014054: IRS discusses partnership items when no return was filed
Chief Counsel advice states that the absence of a filed partnership return does not prevent the IRS from determining partnership items. It relies on section 6221, which permits partnership items to…
CCA 201014053: IRS discusses using an FPAA to determine one partnership item
Chief Counsel advice questions the need for a substitute for return when the IRS seeks to determine only one partnership item. It states that if a TEFRA partnership exists for the redacted matter,…
TAM 201014052: IRS identifies separate properties for a telecommunications casualty loss
The IRS technical advice memorandum analyzes the proper identifiable property units for calculating casualty losses sustained by a telecommunications company. It concludes that the central office…
TAM 201014051: IRS analyzes employment taxes for nonresident alien flight attendants
The IRS technical advice memorandum analyzes U.S. income-tax withholding, FICA, and FUTA treatment for nonresident alien flight attendants employed by a certified U.S. air carrier. It concludes that…
CCA 201014050: IRS analyzes domestic production gross receipts from a licensed product
Chief Counsel advice analyzes whether receipts from a product containing a redacted biological characteristic qualify as domestic production gross receipts under section 199. It concludes that…
PLR 201014049: IRS addresses parent-stock compensation and reimbursement payments
The IRS addressed a publicly traded parent’s stock-based compensation plan for employees of disregarded subsidiaries. The parent transferred stock to employees who exercised stock options or settled…
PLR 201014048: IRS approves an F reorganization and related stock transactions
The IRS approved a proposed cross-border restructuring in which a controlled foreign subsidiary would merge into a new company, the new company would be held through a newly corporatized holding…
PLR 201014047: IRS supplements an earlier ruling on a section 355 distribution
The IRS supplemented an earlier private letter ruling concerning an internal and external distribution of a controlled corporation’s stock. The updated facts included entity conversions, changes in…
PLR 201014046: IRS grants more time for a section 1.337(d)-2(c) election
The IRS granted a consolidated group an extension of time to file a section 1.337(d)-2(c) statement concerning a loss on the stock of a subsidiary. The group had discovered that the election was not…
PLR 201014045: IRS rules on a state-funded retiree health-benefits trust
The IRS ruled on a state-funded entity’s retiree health-benefits plan and related trust. It concluded that the trust’s income was derived from an essential governmental function and accrued to a…
PLR 201014044: IRS approves a qualified personal residence trust modification
The IRS ruled on a proposed modification to a qualified personal residence trust holding a residence for a settlor and family members. The modification would allow the adult remainder beneficiaries…
PLR 201014043: IRS approves a charitable remainder unitrust reformation
The IRS approved a proposed judicial reformation of a charitable remainder unitrust. The trust instrument mistakenly required a charitable remainder beneficiary to qualify under § 170(b)(1)(A), even…
PLR 201014042: IRS rules on a REIT’s lease to an independent contractor
The IRS ruled on a real estate investment trust’s plan to lease office space to an independent construction contractor that also provided services at the REIT’s properties. The lease would be…
PLR 201014041: IRS grants more time for a tax-exempt controlled-entity election
The IRS granted a tax-exempt controlled entity an extension of time to make an election under § 168(h)(6)(F)(ii). The taxpayer had filed its return on time but inadvertently omitted the election,…
PLR 201014040: IRS rules on excluding a physical-injury settlement payment
The IRS ruled on a lump-sum payment received under a settlement agreement for a claim involving personal physical injury and related emotional distress. The taxpayer represented that no part of the…
PLR 201014039: IRS grants late-election relief for S-corporation status
The IRS granted a corporation relief for failing to timely file Form 2553, the S-corporation election form. The corporation established reasonable cause for the late filing and requested an…
PLR 201014038: IRS grants late rental-real-estate election relief
The IRS granted married taxpayers an extension of time to make an election under section 469(c)(7) to treat all of their rental real-estate interests as a single rental real-estate activity. The…
PLR 201014037: IRS grants late-election relief for S-corporation status
The IRS granted a corporation relief for failing to timely file Form 2553, the S-corporation election form. The corporation established reasonable cause for the late filing and requested recognition…
PLR 201014036: IRS grants late-election relief for S-corporation status
The IRS granted a corporation relief for failing to timely file Form 2553, the S-corporation election form. The corporation intended its S election to be effective from the beginning of its first…
PLR 201014035: IRS treats an S-election termination as inadvertent
The IRS ruled that a corporation’s S-election termination was inadvertent after a partnership became the owner of its stock. The partnership was later transferred to one owner, changing its federal…
PLR 201014034: IRS approves a tax-exempt employer’s § 457(b) plan
The IRS ruled that a tax-exempt employer’s restated deferred-compensation plan qualified as an eligible plan under section 457(b). The plan allowed selected employees to defer compensation until…
PLR 201014033: IRS rules on intercompany debt after a subsidiary dissolution
The IRS ruled on federal income-tax consequences after a subsidiary merged into another member of a consolidated group. The ruling addressed a note with accrued interest, an intercompany account,…
PLR 201014032: IRS grants late GST-exemption allocation relief
The IRS granted married taxpayers an extension of time to allocate generation-skipping transfer tax exemption to their respective shares of a charitable lead annuity trust transfer. The taxpayers…
PLR 201014031: IRS grants late entity-classification election relief
The IRS granted an eligible business entity an extension of time to file Form 8832 and elect to be treated as a corporation for federal tax purposes. The entity had inadvertently failed to file the…
PLR 201014030: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014029: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014028: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014027: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014026: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014025: IRS grants late disregarded-entity election relief
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014024: IRS grants a foreign entity more time to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014023: IRS grants a foreign entity more time to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014022: IRS grants a foreign entity more time to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the…
PLR 201014021: IRS grants a foreign entity more time to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file 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.