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 201007015: IRS granted extra time for a foreign entity 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 intended the election to be…
PLR 201007014: IRS granted extra time for a foreign entity 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 intended the election to be…
PLR 201007013: IRS granted extra time for a foreign entity 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 intended the election to be…
PLR 201007012: IRS granted extra time for a foreign entity 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 intended the election to be…
PLR 201007011: IRS granted extra time for a foreign entity 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 intended the election to be…
PLR 201007010: IRS granted extra time for a foreign entity 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 intended the election to be…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Extension granted to file an entity classification election
The IRS granted a foreign single-owner entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that…
Five-year extension granted for amortizing unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of December 1, 2008. The extension was granted under section 431(d)(1) of the Internal Revenue…
IRS letter 201006036: Five-year extension granted for amortizing unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of January 1, 2009. The extension was granted under section 431(d)(1) of the Internal Revenue…
PLR 201006035: Waiver of the 60-day IRA rollover requirement denied
The IRS declined to waive the 60-day rollover requirement for an individual who withdrew money from an IRA and deposited it into a non-IRA account. The taxpayer said he was unfamiliar with the IRA…
IRS letter 201006034: Five-year extension granted for amortizing unfunded liabilities
The IRS approved a five-year automatic extension for a pension plan to amortize unfunded liabilities as of November 1, 2008. The extension was granted under section 431(d)(1) of the Internal Revenue…
PLR 201006033: Employer-related scholarship grant program approved
The IRS approved a private foundation's proposed employer-related scholarship grant program for dependent children of employees. The program required objective and nondiscriminatory selection by an…
IRS letter 201006032: Private letter ruling revoked
The IRS revoked private letter ruling 200709065, effective November 25, 2009. The letter says the revocation concerns an organization and will be made available for public inspection after…
TAM 201006031: General surplus declaration was not deductible as a policyholder dividend
The IRS analyzed whether a workers’ compensation self-insurance trust could deduct a general declaration of surplus as a policyholder dividend in the year it was declared. The trust’s members were…
TAM 201006030: General surplus declaration was not deductible as a policyholder dividend
The IRS analyzed whether a workers’ compensation self-insurance trust could deduct a general declaration of surplus as a policyholder dividend in the year it was declared. The trust’s members were…
TAM 201006029: General surplus declaration was not deductible as a policyholder dividend
The IRS analyzed whether a workers’ compensation self-insurance trust could deduct a general declaration of surplus as a policyholder dividend in the year it was declared. The trust provided…
CCA 201006028: Homebuilder warranty repairs were not product-liability losses
Chief Counsel analyzed whether a tract homebuilder’s liabilities for repairing homes under its warranties qualified as product liabilities under section 172(f)(4). The homebuilder repaired…
TAM 201006027: Transfer of major business portions required a section 936 income adjustment
The IRS analyzed whether a corporation claiming the former section 936 possession tax credit had to adjust its adjusted base period income after transferring major portions of its Puerto Rico…
PLR 201006026: Disproportionate distributions did not terminate S corporation status
The IRS ruled that disproportionate distributions by an S corporation to its shareholders did not create a second class of stock. The corporation represented that all shares had identical rights to…
PLR 201006025: IRS granted relief for a late S corporation election
The IRS determined that a corporation had reasonable cause for failing to timely file its S corporation election. It ruled that the election could be treated as timely for the intended effective…
PLR 201006024: IRS extended time for a consolidated-return waiver election
The IRS granted a domestic corporation more time to request an automatic waiver of the limitation on including a previously disaffiliated subsidiary in a consolidated return. The corporation…
PLR 201006023: Trust reformation and settlement did not trigger GST tax
The IRS ruled on the estate, gift, and generation-skipping transfer tax consequences of modifying a trust under a court-approved settlement agreement. A court had reformed a trust provision to make…
PLR 201006022: IRS extended time for a consolidated loss election
The IRS granted a consolidated group 45 more days to make an election concerning the basis reduction and loss-disallowance treatment of a subsidiary’s stock after the subsidiary went public and left…
PLR 201006021: RIC returns treated as timely for late elections
The IRS granted seven regulated investment company funds relief for late elections under sections 853 and 855(a). Each fund intended to elect under section 855(a) to treat certain dividends paid…
PLR 201006020: IRS extended time for a Taxable REIT Subsidiary election
The IRS granted a real estate investment trust and its wholly owned corporation 60 days to make a late election treating the corporation as a Taxable REIT Subsidiary under section 856(l). The…
PLR 201006019: IRS granted relief for a late S corporation election
The IRS determined that a corporation had reasonable cause for failing to timely file its S corporation election. It ruled that the election could be treated as timely if the corporation filed a…
PLR 201006018: IRS granted relief for a late S corporation election
The IRS granted a corporation relief under section 1362(b)(5) after its S corporation election was not timely filed. The corporation could be treated as an S corporation effective as of its intended…
PLR 201006017: S corporation status restored after an untimely ESBT election
The IRS ruled that a corporation’s S corporation status terminated when stock was transferred to a trust that did not timely make an Electing Small Business Trust election. The corporation…
PLR 201006016: IRS granted more time for an insurance company’s section 831(b) election
The IRS granted an insurance company a six-month extension to make an election under section 831(b), which provides an alternative tax for eligible insurance companies other than life insurance…
PLR 201006015: Debt-repurchase income qualified as RIC qualifying income
The IRS ruled that discharge-of-indebtedness income arising when a regulated investment company repurchased certain debt instruments at a discount could be qualifying income under section 851(b)(2).…
PLR 201006014: IRS extended time for a partnership classification election
The IRS granted a limited liability company 60 more days to file Form 8832 and elect partnership classification for federal tax purposes. The company had two owners, was eligible for partnership…
PLR 201006013: IRS granted relief for a late S corporation election
The IRS granted a corporation relief under section 1362(b)(5) after its S corporation election was not timely filed. The corporation could be treated as an S corporation effective as of its intended…
PLR 201006012: Proposed residence trust modification avoided section 2702 treatment
The IRS ruled on a proposed modification to a qualified personal residence trust involving a residence originally transferred by a parent who retained a term interest. The modification would allow…
PLR 201006011: Bonus plan participant is not entitled to depletion deductions
The IRS considered whether an employee participating in a company bonus plan could claim depletion deductions. The plan calculated bonuses from the net profits of designated oil, gas, and mineral…
PLR 201006010: IRS treats a possibly terminated S corporation election as continuing
The IRS considered whether a corporation's S corporation election continued after the corporation issued stock warrants in debt financing transactions. The warrants may have created a second class…
PLR 201006009: Spouses receive more time to allocate GST exemption to family trusts
The IRS granted a donor and spouse more time to allocate their generation-skipping transfer tax exemption to three family trusts. The company's chief financial officer failed to retain an accounting…
PLR 201006008: Spouses receive more time to allocate GST exemption to two family trusts
The IRS granted a donor and spouse more time to allocate their generation-skipping transfer tax exemption to two family trusts. The company's chief financial officer failed to retain an accounting…
PLR 201006007: Foreign entity receives more time to elect corporate classification
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity intended to make the…
PLR 201006006: Foreign entity receives more time to elect disregarded-entity status
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 company intended the election to be effective on its…
PLR 201006005: Trust modifications do not cause loss of GST-tax-exempt status
The IRS approved several proposed changes to an irrevocable family trust created before September 25, 1985. A court had reformed the trust to clarify that a beneficiary held a limited, rather than…
PLR 201006004: Coal dispositions qualify for section 631(c) treatment
The IRS ruled that an S corporation's dispositions of coal interests in three properties qualified as dispositions with a retained economic interest under section 631(c). The resulting gains or…
PLR 201006003: Consolidated group may claim a worthless-stock deduction after a subsidiary merger
The IRS ruled that a consolidated group may claim a worthless-stock deduction for stock of a wholly owned subsidiary when the subsidiary transfers its assets to the parent in a proposed merger. The…
PLR 201006002: Related life insurers may complete two tax-free exchanges with limited gain recognition
The IRS ruled that two proposed exchanges of insurance businesses, assets, and liabilities between related life insurance companies qualify under IRC § 351. The first exchange may occur without gain…
PLR 201006001: Taxpayer may make a retroactive qualified electing fund election
The IRS consented to a taxpayer's retroactive qualified electing fund election for an investment in a foreign corporation. The taxpayer had relied on a tax professional who did not identify the…
TAM 201005061: Discount-certificate sales are taxable unrelated business income but do not end exemption
The IRS advised that a trade association's sale of discount certificates to the public generated unrelated business taxable income. The certificates promoted and provided discounts at particular…
Determination 201005060: IRS revokes exemption for organization operating a private-benefit debt-management program
The IRS issued a final adverse determination revoking an organization's recognition as exempt under IRC § 501(c)(3), effective January 1, 2002. The IRS concluded that the organization did not…
PLR 201005059: Surviving spouse may make a late rollover of inherited retirement funds
The IRS determined that distributions from a deceased spouse's IRA and SEP-IRA were eligible rollover distributions for the surviving spouse. The spouse was the sole successor trustee of a trust…
PLR 201005058: IRS waives the 60-day rollover deadline after custodian error
The IRS waived the 60-day rollover requirement for a taxpayer who moved funds from an IRA to invest through a new IRA but, because of errors by two companies, the funds were placed in a non-IRA…
PLR 201005057: Direct rollover treatment applies to a check payable to the new plan
The IRS concluded that a former employee's check from an employer-sponsored plan was a direct rollover rather than a distribution subject to the 60-day rollover deadline. The check was made payable…
PLR 201005056: IRS declines a late rollover waiver for distributed life-insurance policies
The IRS declined to waive the 60-day rollover requirement for a taxpayer who received life-insurance policies and cash from a terminated defined-contribution plan. The taxpayer said the plan…
Determination 201005055: Additional charitable-facility set-aside qualifies as a distribution
The IRS approved a private operating foundation's additional set-aside for the expansion and redevelopment of a charitable facility. The foundation represented that the project would support…
Determination 201005054: Additional set-aside for charitable facility project qualifies
The IRS approved an additional income set-aside for a private operating foundation's charitable facility project. The foundation represented that the project would support services for children and…
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.