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 201012032: LLC granted more time to make a section 754 election
The IRS granted a limited liability company treated as a partnership an additional 60 days to make a section 754 election. The company had redeemed four partners, and its tax advisor had failed to…
PLR 201012031: LLC granted more time to make a section 754 election
The IRS granted a limited liability company treated as a partnership an additional 60 days to make a section 754 election. The company had redeemed four partners, and its tax advisor had failed to…
PLR 201012030: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012029: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012028: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012027: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012026: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012025: 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 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election…
PLR 201012024: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity represented that it was eligible for that…
PLR 201012023: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity represented that it was eligible for that…
PLR 201012022: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had defaulted to association treatment, was eligible…
PLR 201012021: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had defaulted to association treatment, was eligible…
PLR 201012020: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had defaulted to association treatment, was eligible…
PLR 201012019: Foreign entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had defaulted to association treatment, was eligible…
PLR 201012018: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012017: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012016: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012015: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012014: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012013: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012012: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012011: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012010: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012009: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012008: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012007: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012006: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012005: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012004: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012003: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012002: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012001: Entity granted more time to elect disregarded-entity treatment
The IRS granted a foreign entity 60 days to file a properly executed Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to take…
PLR 201012054: IRS grants a conditional minimum-funding waiver for a pension plan
The IRS granted a conditional waiver of the minimum funding standard for a pension plan for the plan year ending June 30, 2007. The waiver requires collateral acceptable to the Pension Benefit…
PLR 201012053: IRS waives the 60-day rollover requirement after financial-institution errors
The IRS waived the 60-day rollover requirement for a taxpayer who intended to move the balance of a SEP-IRA into a new SEP-IRA. The financial institution returned the taxpayer’s check and failed to…
IRS denies section 501(c)(6) exemption to an organization serving its members
The IRS issued a final adverse determination that an organization did not qualify for exemption under section 501(c)(6). The organization coordinated public-private infrastructure projects, charged…
PLR 201012050: LLC interest contributions avoid self-dealing treatment but remain subject to bargain-sale rules
The IRS ruled that a married couple’s contribution of LLC interests to a private foundation would not be self-dealing under section 4941 on the facts presented. The LLC’s liabilities were treated as…
Determination 201011037: IRS revoked an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 2004. The organization had stopped holding its annual show, had little documented exempt activity, and mainly…
PLR 201011036: Disability exception applies to early unequal IRA withdrawals
The IRS approved a ruling for a taxpayer under age 59½ who had multiple sclerosis and received Social Security disability benefits. The taxpayer planned to take unequal, nonperiodic withdrawals from…
PLR 201011035: Endowment unit contracts for charitable remainder trusts do not create unrelated business income
The IRS ruled that a publicly supported section 501(c)(3) organization could issue contractual units in its investment endowment to charitable remainder trusts for which it served as trustee and…
PLR 201011034: Trust reformation preserves charitable remainder unitrust status and avoids self-dealing
The IRS approved a proposed court-ordered reformation of a charitable remainder unitrust. The trust agreement mistakenly required the remainder beneficiary to be a public charity, even though the…
Tax matters partner's power of attorney does not represent other partners
Chief Counsel advice addressed whether the power of attorney for a tax matters partner also represented the tax matters partner's other partners. The advice stated that the power of attorney…
Employer-paid disability coverage makes benefits taxable
Chief Counsel advice concluded that disability amounts received under a settlement agreement would be fully taxable if they were disability benefits paid under the taxpayer's employer's group…
Branch declines transferee-liability issue outside its withholding jurisdiction
Chief Counsel advice addressed a question about transferee liability involving foreign corporate shareholders. The branch stated that it did not handle transferee-liability questions except possibly…
One-year assessment period begins after partner identification compliance
Chief Counsel advice addressed when the one-year period under section 6229(e) begins to run for an unidentified partner. The advice stated that the period would not begin until the partner complied…
Generic tax matters partner FPAAs are permissible
Chief Counsel advice addressed whether a proceeding needed a named tax matters partner. The advice stated that a named tax matters partner was not necessary because the regulations and courts…
Kicked-out partner may automatically become tax matters partner
Chief Counsel advice stated that if a kicked-out partner was a member-manager during the audit year, that partner was automatically the tax matters partner under the largest-profits-interest rule.…
Section 6229(e)(2)(B) coverage depends on a timely FPAA or inconsistent filing
Chief Counsel advice addressed when the IRS was covered by section 6229(e)(2)(B) in connection with unidentified investors. The advice stated that the provision applied only if the IRS issued an…
TEFRA exception requires reasonable reliance on the return
Chief Counsel advice addressed whether the exception in section 6231(g)(2) could apply when two partnerships were obviously subject to TEFRA based on their Forms 1065 and K-1s. The advice stated…
Non-TEFRA deficiency notice does not suspend the partnership-item statute
Chief Counsel advice addressed whether a non-TEFRA notice of deficiency suspended the statute of limitations for partnership items. The advice stated that although the IRS could rely on a partner's…
Form 8821 grants information access, not taxpayer representation authority
Chief Counsel advice clarified the references to Forms 2848 and 8821 in the representation section of Letter 1153. It confirmed that Form 8821 does not authorize an appointee to represent a taxpayer…
Tax matters partner may file as notice partner if qualified
Chief Counsel advice stated that a tax matters partner could file as a notice partner if the partner met all requirements for being a tax matters partner. The advice cited Barbados #6 v.…
FPAA should issue to the source tier showing a working interest
Chief Counsel advice addressed which partnership tier should receive an FPAA when a working interest was shown in a tiered structure. The advice stated that the IRS should issue the FPAA to the…
Imported tires brought into Puerto Rico are not subject to the tire excise tax
Chief Counsel Advice addressed whether a Puerto Rican company that imported tires from abroad was subject to the excise tax on taxable tires. The advice concluded that the company was not an…
Failure to report inconsistent treatment can trigger an accuracy penalty
Chief Counsel Advice addressed a partner's failure to notify the IRS about inconsistent treatment of a partnership item. It cited the Schedule K-1 instructions, which require the partner to file…
Section 6501(k) applies to the remaining refund after an NOL carryback recovery
Chief Counsel Advice confirmed an interpretation involving the interaction of IRC §§ 6501(k) and 6501(h) after a net operating loss carryback. The advice described section 6501(k) as applying to the…
Refund claims can open a broader assessment period for carryback-related deficiencies
Chief Counsel Advice discussed the assessment periods that apply when a net operating loss is carried back and the taxpayer seeks a tentative refund under IRC § 6411. Under section 6501(h), the IRS…
Materials for National Office review of section 6015(f) cases
Chief Counsel Advice described materials that generally should be submitted to the National Office for review in cases involving claims for relief under IRC § 6015(f). The list included dispositive…
Filing a section 6228(b) suit converts all partnership items for that year
Chief Counsel Advice interpreted the taxable year covered by the phrase “to which such part of such request relates” in IRC § 6228(b)(2)(A)(ii). It stated that IRC § 6231(b)(1)(B) confirms the…
An FPAA may address a section 754 election and disregarded-entity income
Chief Counsel Advice considered a proposal involving a partnership return filed by a disregarded entity. The advice stated that an FPAA could determine that a section 754 election was invalid and…
Jointly liable items may be challenged after a statutory notice issues
Chief Counsel Advice addressed whether W could challenge items for which she was jointly liable with H. It stated that W could challenge all such items if the IRS issued a statutory notice. If H…
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.