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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
IRS denies VEBA exemption application for private inurement and impermissible benefits
The IRS denied a trust's application for exemption under IRC § 501(c)(9). The analysis concluded that the trust primarily benefited a highly compensated owner and his wife, lacked an independent…
Private foundation's M.D.-Ph.D. scholarship procedures approved
The IRS approved a private foundation's procedures for awarding up to five scholarships each year to students pursuing an M.D.-Ph.D. degree. The procedures included an objective selection process,…
Exemption denied for corporation leasing facilities to charter schools
The IRS denied an organization's application for exemption under IRC § 501(c)(3). The organization planned to acquire, renovate, and lease facilities to unrelated charter schools, and also described…
PLR 200950046: IRS approves employer-related scholarship procedures
The IRS approved a private foundation's procedures for funding scholarships for children and relatives of an employer's employees through an independent public charity. The procedures used…
PLR 200950045: IRS approves scholarship and project grant procedures
The IRS approved a private foundation's procedures for awarding scholarships and project grants to individuals. Scholarships could support undergraduate or graduate study, while project grants could…
CCA 200950044: IRS guidance on summons authority and procedures
This Chief Counsel Advice answers frequently asked questions about IRS summonses. It discusses what records and testimony a summons may seek, the differences between first-party, third-party, and…
CCA 200950043: IRS identifies military survivor annuities covered by levy protection
This Chief Counsel Advice explains which military survivor annuities are referenced by IRC § 6334(a)(6). The advice states that the provision covers annuities paid to certain surviving spouses and…
CCA 200950042: electronic refund transfers can be prohibited negotiations
This Chief Counsel Advice addresses whether IRC § 6695(f) prohibits a tax return preparer from exercising control over a taxpayer's electronic refund. It explains that the Uniform Commercial Code,…
CCA 200950041: filing-date treatment under IRC §§ 6404(g) and 7502
This Chief Counsel Advice addresses whether the IRS should treat a return as filed on the same date for IRC § 7502, which concerns timely mailing and filing, and IRC § 6404(g), which concerns…
CCA 200950040: overview of tax shelter registration and investor-list penalties
This Chief Counsel Advice forwards slides summarizing promoter-penalty rules for tax shelters. The slides describe registration under IRC § 6111, the duty to maintain investor lists under § 6112,…
CCA 200950039: IRS points to prior guidance on crab license buybacks
This Chief Counsel Advice concerns a program to buy back Oregon fishing permits to reduce fishing capacity on the Pacific Coast. It states that a proposed Virginia crab license buyback program was…
CCA 200950038: third-party address information generally does not change last known address
This Chief Counsel Advice discusses whether information from a taxpayer's latest information-return document or a signed state return can change the taxpayer's last known address. It states that,…
CCA 200950037: IRS training materials explain façade-easement contribution rules and penalties
This Chief Counsel Advice consists of training slides on charitable contributions of façade easements. It explains when a façade easement can qualify as a conservation contribution under IRC §…
CCA 200950036: Training slides explain dividend strips and related-corporation stock sales
This Chief Counsel Advice contains training materials about “strip and sell” transactions involving corporate stock, earnings and profits, dividends, and basis. The slides explain how a corporate…
PLR 200950035: IRS permits an entity to change to disregarded-entity status within the 60-month period
The IRS permitted an eligible entity to elect disregarded-entity status for federal tax purposes even though the election would occur within 60 months of an earlier entity-classification election.…
PLR 200950034: IRS grants late S corporation election relief
The IRS granted a corporation relief for failing to timely file Form 2553 to elect S corporation status. The corporation was formed in the state identified in the ruling and intended its S election…
PLR 200950033: IRS grants more time to make section 59(e) elections
The IRS granted a taxpayer an extension of time to make elections under IRC § 59(e) for three taxable years. The taxpayer timely filed its returns, but its authorized officer did not make the…
PLR 200950032: IRS approves limited charitable distributions from a CRAT
The IRS approved a proposed modification to a charitable remainder annuity trust, or CRAT. The trust would continue paying the surviving annuity recipient while allowing its charitable trustee to…
PLR 200950031: IRS grants late section 754 election relief
The IRS granted a limited liability company 60 days to make a late IRC § 754 election effective for the specified tax year. The company had timely filed its partnership return, but its election to…
PLR 200950030: IRS consents to a retroactive QEF election for a PFIC investment
The IRS consented to a taxpayer’s retroactive qualified electing fund, or QEF, election for an investment in a passive foreign investment company. The taxpayer was a U.S. citizen and beneficiary of…
PLR 200950029: IRS consents to a retroactive QEF election for a PFIC investment
The IRS consented to a taxpayer’s retroactive qualified electing fund, or QEF, election for an investment in a passive foreign investment company. The taxpayer was a U.S. citizen and beneficiary of…
PLR 200950028: IRS consents to a retroactive QEF election for a PFIC investment
The IRS consented to a taxpayer’s retroactive qualified electing fund, or QEF, election for an investment in a passive foreign investment company. The taxpayer was a U.S. citizen and beneficiary of…
PLR 200950027: IRS consents to a retroactive QEF election for a PFIC investment
The IRS consented to a taxpayer’s retroactive qualified electing fund, or QEF, election for an investment in a passive foreign investment company. The taxpayer was a U.S. citizen and beneficiary of…
PLR 200950026: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950025: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950024: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950023: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950022: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950021: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950020: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950019: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950018: IRS permits a taxpayer to make a retroactive QEF election for PFIC shares
The IRS considered a U.S. citizen's request to make a retroactive qualified electing fund (QEF) election for shares held through a foreign trust. The taxpayer said the trustees, including a…
PLR 200950017: IRS treats a captive reinsurer as an insurance company for federal tax purposes
The IRS considered whether a captive company’s quota-share arrangement with a foreign segregated cell insurance company was insurance for federal income tax purposes. The arrangement covered risks…
PLR 200950016: IRS treats a captive reinsurer as an insurance company for federal tax purposes
The IRS considered whether a captive company’s quota-share arrangement with a foreign segregated cell insurance company was insurance for federal income tax purposes. The arrangement covered risks…
PLR 200950015: IRS grants extra time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity was eligible to make the election, but…
PLR 200950014: IRS grants extra time to make a DISC election
The IRS granted a domestic corporation an additional 60 days to file Form 4876-A and elect interest-charge DISC status for its first taxable year. The corporation had intended to be treated as a…
PLR 200950013: IRS allows mine-by-mine aggregation of royalty interests
The IRS granted a taxpayer extra time to apply to aggregate separate nonoperating mineral interests and then permitted the taxpayer to aggregate royalty interests on a mine-by-mine basis. The…
CCA 200950012: Quarterly Form 941 limitation periods apply separately
Chief Counsel advised that quarterly Forms 941 should be treated as separate returns when calculating the periods for assessing employment tax and claiming refunds or credits. The filing dates for…
PLR 200950011: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950010: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950009: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950008: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950007: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950006: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950005: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950004: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950003: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950002: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
PLR 200950001: IRS accepts a late Form 1128 to change the taxpayer’s year end
The IRS treated a taxpayer’s late-filed Form 1128 as timely for a requested change in accounting period. The taxpayer had intended to make the change on time, but an error or misunderstanding caused…
Determination 200949055: Private foundation grant procedures received advance approval
The IRS gave advance approval to a private foundation’s grant-making program under IRC § 4945(g)(3). The organization plans to provide financially need-based grants to children and young adults for…
PLR 200949054: IRS waives the 60-day IRA rollover deadline after financial-institution error
The IRS waived the 60-day rollover requirement for a married couple after a financial institution gave them erroneous advice about required minimum distributions. The couple withdrew amounts from…
PLR 200949053: IRS waives the 60-day rollover deadline after a bank deposits funds into the wrong account
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from a former employer's 401(k) plan. The taxpayer instructed a bank to deposit the funds into an IRA, but…
PLR 200949052: IRS grants extra time for a rollover delayed by the taxpayer’s mother’s death
The IRS waived the 60-day rollover requirement for a taxpayer who received a distribution from an employer plan. The taxpayer had intended to roll the funds into an IRA, but his terminally ill…
PLR 200949051: IRS permits a limited rollover after health conditions delayed an IRA transfer
The IRS waived the 60-day rollover requirement for a taxpayer whose mental and physical conditions impaired her ability to manage her financial affairs. The distribution came from an IRA, and some…
PLR 200949050: IRS waives the rollover deadline after a financial institution delays an IRA transfer
The IRS waived the 60-day rollover requirement for a taxpayer who transferred funds from one IRA to another. The taxpayer completed an application for an IRA annuity within the 60-day period, but…
CCA 200949049: IRS deed must match the property advertised in the notice of sale
Chief Counsel Advice addresses a discrepancy between the legal description in a notice of seizure and the real property actually sold by the IRS. It states that the notice of seizure must describe…
CCA 200949048: Revenue agents may inspect premises when a direct visit is needed
Chief Counsel Advice addresses when a revenue agent may inspect a taxpayer's business or residence. It states that IRC §§ 7602(a) and 7605(a) authorize examination of the taxpayer's facilities,…
CCA 200949047: Examiner guidance on TEFRA procedures and small partnerships
Chief Counsel Advice discusses when an examiner should apply the TEFRA partnership procedures and the small partnership exception. It states that section 6231(g) permits the Service to determine…
CCA 200949046: Unclaimed deficiency notices and challenges to underlying liability in CDP hearings
Chief Counsel Advice addresses whether a taxpayer may challenge an underlying tax liability during a collection due process hearing when a statutory notice of deficiency was returned to the IRS as…
CCA 200949045: Options for handling unpaid overassessments in AAR cases
Chief Counsel Advice addresses how the IRS may handle an overassessment when taxpayers have not yet paid it. The advice states that the Service could abate the overassessment or refer the matter to…
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.