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 201014020: 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 201014019: 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 201014018: 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 201014017: 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 201014016: 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 201014015: 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 201014014: 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 201014013: 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 201014012: 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 201014011: 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 201014010: 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 201014009: 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 201014008: 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 201014007: 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 201014006: 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 201014005: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832. The entity had failed to make its classification election on time and wanted to be treated as a disregarded entity…
PLR 201014004: Late mark-to-market election denied because the request involved hindsight
The IRS denied a taxpayer's request for extra time to elect the mark-to-market accounting method for securities traders under section 475(f). The taxpayer said that tax professionals had not…
PLR 201014003: Retroactive qualified electing fund election approved for a foreign investment
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a foreign corporation. The corporation was later identified as a passive foreign investment…
PLR 201014002: Foreign subsidiary conversion and related stock transactions receive limited ruling conclusions
The IRS addressed selected federal tax consequences of a multinational group's proposed restructuring of foreign subsidiaries. The plan included transfers of stock, a conversion of a foreign…
PLR 201014001: Public fund investments will not make variable contract holders the owners of fund shares
The IRS ruled that a new fund of funds could invest in publicly offered funds without causing variable life or annuity contract holders to be treated as the owners of the new fund's shares for…
IRS 201013075: Section 501(c)(3) exemption revoked after operational examination
The IRS revoked a nonprofit organization's recognition as exempt under section 501(c)(3), effective on the redacted date of its formation. The examination report concluded that the organization did…
IRS 201013074: Five-year amortization extension approved for an unfunded pension liability
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities existing on December 1, 2008. The extension applies to eligible amortization charge bases that…
PLR 201013073: 60-day IRA rollover requirement waived after an unintended distribution
The IRS waived the 60-day rollover requirement for a taxpayer whose IRA distribution was transferred to a nonqualified account without the taxpayer's knowledge or consent. The taxpayer said that a…
PLR 201013072: Private foundation's permitted holdings and dividend income approved
The IRS ruled that a private foundation could hold certain nonvoting stock and all of a newly created class of voting stock in an employee-owned corporation without creating excess business holdings…
PLR 201013071: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities that existed as of January 1, 2009. The extension applied to eligible amortization charge bases…
PLR 201013070: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1 of the relevant year. The extension applied to eligible amortization charge…
PLR 201013069: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applied to amortization charge bases identified in the…
PLR 201013068: IRS approves a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities as of January 1, 2009. The extension applied to eligible amortization charge bases established…
PLR 201013067: IRS waives the 60-day rollover deadline after incorrect financial-institution advice
The IRS waived the 60-day deadline for a taxpayer to roll amounts distributed from two individual retirement accounts into an IRA. The taxpayer had relied on incorrect advice from a financial…
PLR 201013066: Private foundation may transfer all assets to another foundation and dissolve
The IRS ruled on a private foundation's plan to transfer all of its assets to another private foundation with identical exempt purposes and then dissolve. The transfer would not voluntarily…
PLR 201013065: Private foundation may transfer all assets to another foundation and dissolve
The IRS ruled on a private foundation's plan to transfer all of its assets to another private foundation with identical exempt purposes and then dissolve. The transfer would not voluntarily…
Revocation 201013064: IRS revokes a one-person organization's section 501(c)(3) exemption
The IRS revoked a nonprofit organization's section 501(c)(3) exemption after an examination found that its income and assets were repeatedly used for private purposes. The organization was…
Revocation 201013063: IRS revokes exemption after an organization fails to provide examination records
The IRS revoked an organization's section 501(c)(3) exemption after the organization failed to provide information and records needed to examine its exempt status. The IRS determined that the…
Revocation 201013062: IRS revokes exemption after clinic operations and compliance failures
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The examination found that the organization had shifted from education and charitable assistance to fee-based…
Revocation 201013061: IRS revokes exemption after finding a commercial debt-management purpose
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization sold and administered debt-management plans, and the IRS concluded that this activity…
Revocation 201013060: IRS revokes exemption over member ownership and private benefit
The IRS revoked an organization's section 501(c)(4) exemption retroactively to January 1, 20XX. The document describes the golf course as the organization's primary activity in the gross receipts…
Revocation 201013059: IRS revokes exemption after failure to provide records and file returns
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization failed to provide information requested for an examination of its Form 990 and failed to…
Revocation 201013058: IRS revokes exemption after an organization fails to file and provide records
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization failed to respond to repeated IRS requests to examine its records and failed to file Form…
Revocation 201013057: IRS revokes exemption after failure to file and provide records
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization failed to file Form 990 and did not respond to repeated IRS requests for records about its…
Revocation 201013056: IRS revokes exemption after a low-income housing organization becomes inactive
The IRS revoked an organization's section 501(c)(3) exemption effective April 1, 20XX. The organization had provided low-income housing for senior citizens and people with disabilities, but sold its…
Revocation 201013055: IRS revokes social-club exemption after excessive nonmember receipts
The IRS revoked a social club's section 501(c)(7) exemption. The club operated facilities including a restaurant, bar, comedy club, reciprocal golf arrangements, banquet hall, meeting room, and…
Revocation 201013054: IRS revokes a veterans organization’s exemption after membership failures
The IRS revoked a veterans organization’s exemption under IRC § 501(c)(19), effective January 1, 20XX. The organization operated a club with a bar and member activities, and the report concluded…
CCA 201013053: IRS advice on relying on a pre-2004 tax opinion against a section 6662A penalty
Chief Counsel advice addressed whether a taxpayer could rely on a tax opinion issued before October 22, 2004, to avoid the accuracy-related penalty under IRC § 6662A. The advice interpreted a…
CCA 201013052: IRS advice on disqualifying a profit-sharing plan after questioned transfers
Chief Counsel advice considered whether the tax benefit rule or a duty-of-consistency argument could support action against a profit-sharing plan. The memorandum discussed a possible plan…
CCA 201013051: IRS explains when merged subsidiaries join a consolidated group
Chief Counsel advice considered whether subsidiaries of one corporation became members of another corporation’s consolidated group on the date of a merger occurring one minute before midnight. The…
CCA 201013050: IRS discusses FICA withholding for nonresident student workers
Chief Counsel advice discussed withholding and FICA issues for nonresident alien students. It stated that special withholding procedures may be needed for the Making Work Pay Credit and that…
CCA 201013049: IRS explains penalty assertions in a notice of adjustment
Chief Counsel advice addressed what should be asserted in a notice of adjustment under IRC § 6234. It said the notice should assert the adjustments and the applicability of the 20% or 40% penalty.…
CCA 201013048: IRS comments on the status of bonds and depreciation
Chief Counsel advice addressed the status of certain bonds discussed in a focus-group presentation. The memorandum stated that the issue appeared to involve how a case is handled when the underlying…
CCA 201013047: IRS accepts a Form 872 extension for partnership taxes
Chief Counsel advice addressed whether a Form 872 consent extending the assessment period was acceptable for a partnership’s taxes. The memorandum stated that the form was sufficient and assumed…
CCA 201013046: IRS addresses TEFRA limitation-period suspension after an untimely petition
Chief Counsel advice addressed whether filing an untimely petition in a TEFRA case suspends the statute of limitations. It stated that the suspension rule applies to any petition under IRC § 6226,…
CCA 201013045: IRS distinguishes units of property used for depreciation and retirement
Chief Counsel advice addressed whether the asset, or unit of property, used for depreciation and retirement purposes must be the same as the unit of property used for repair and capitalization…
CCA 201013044: IRS addresses TEFRA computational adjustments and refund claims
Chief Counsel advice addressed several questions about computational adjustments, penalty assessments, and refund claims in a TEFRA partnership matter. It explained when the IRS is treated as having…
CCA 201013043: IRS comments on language for single-member LLCs
Chief Counsel advice addressed language concerning single-member limited liability companies. It stated that the pre-change language may have been accurate based on when services were performed. The…
CCA 201013042: IRS discusses redaction review and release timing
Chief Counsel advice discussed procedures for processing written determinations under IRC § 6110. It identified provisions of the Internal Revenue Manual as relevant and stated that Counsel review…
CCA 201013041: IRS directs where contribution changes belong in an FPAA
Chief Counsel advice addressed how changes to a contribution amount should be recorded in a TEFRA partnership proceeding. It stated that the changes should appear on the Schedule of Adjustments in…
CCA 201013040: IRS approves use of Form 13798-L to designate a TMP
Chief Counsel advice approved a proposed approach concerning designation of a tax matters partner in a TEFRA matter. It clarified that Form 13798-L is the form used to designate a tax matters partner.
CCA 201013039: IRS illustrates stock-loss limits under section 1.337(d)-2
Chief Counsel advice provided a hypothetical example of applying section 1.337(d)-2 and the disconformity method in Notice 2004-58 to a consolidated group subsidiary stock sale. In the initial…
CCA 201013038: IRS denies like-kind treatment for a structured related-party exchange
Chief Counsel advice considered a heavy-equipment dealer arrangement using a qualified intermediary to exchange equipment between related parties. The taxpayer argued that independent business…
CCA 201013037: IRS confirms deferral method for settlement-agreement payments
Chief Counsel advice clarified an earlier memorandum concerning whether a taxpayer could use the deferral method in Rev. Proc. 2004-34 for advance payments received under a settlement agreement. The…
CCA 201013036: IRS approves a fresh-start basis date for Alaska subsurface rights
Chief Counsel advice considered the basis of subsurface rights received by an Alaska Native regional corporation and later sold to the state of Alaska. It concluded that the corporation could value…
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.