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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CCA 200948048: An employee's family member may not translate an interview without taxpayer consent
This Chief Counsel Advice addresses whether a friend or family member may translate an employee interview during a worker-classification investigation. Counsel states that the translator may not…
CCA 200948047: Forms 872-i are valid for the taxpayers who signed them
This Chief Counsel Advice discusses TEFRA proceedings, extensions of the assessment period, and affected items. Counsel states that Forms 872-i are valid for the ultimate taxpayers who signed them.…
CCA 200948046: Revenue Ruling 58-599 treats the United States government as one employer
This Chief Counsel Advice addresses whether the United States government is one employer for purposes of the wage rules. Counsel points to Revenue Ruling 58-599, which states that the federal…
CCA 200948045: A trust listed as a partner makes the partnership subject to TEFRA
This Chief Counsel Advice addresses a partnership listed as a TEFRA partnership because a trust appeared as a partner on the partnership return. Counsel states that the partnership’s TEFRA status…
CCA 200948044: Parent and subsidiary should execute a new Form 870-LT
This Chief Counsel Advice addresses a TEFRA entity and a settlement agreement. Because the parent’s signature is necessary and the limitations period remains open, Counsel recommends that both the…
CCA 200948043: Taxpayer qualifies for Section 530 employment-tax relief for its category of workers
This Chief Counsel Advice concludes that a taxpayer qualifies for relief under Section 530 of the Revenue Act of 1978 for its category of workers. The taxpayer met the reporting consistency…
TAM 200948042: Insurance company may not deduct policyholder dividends before the year they become payable
This Technical Advice Memorandum considers whether an insurance company using the accrual method may deduct annual policyholder dividends before the year they become payable. The IRS concluded that…
PLR 200948041: IRS granted an extension for a late Form 1128 to change the taxpayer's year-end
The IRS treated a corporation's late Form 1128 as timely filed for a requested change from a December 31 tax year to a March 31 tax year. The taxpayer sought relief under Treas. Reg. § 301.9100-3…
PLR 200948040: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948039: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948038: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948037: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948036: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948035: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948034: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948033: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948032: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948031: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948030: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948029: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948028: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948027: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948026: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948025: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948024: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948023: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948022: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948021: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948020: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948019: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948018: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948017: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948016: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948015: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948014: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948013: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948012: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948011: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948010: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948009: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948008: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948007: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948006: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948005: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948004: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948003: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948002: Foreign single-owner entity granted time to elect disregarded-entity status
The IRS granted a foreign single-owner business entity 60 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make…
PLR 200948001: Life-insurance proceeds held outside estate after ownership powers are released
The IRS ruled that proceeds from two life-insurance policies received by a partnership after the insured taxpayer's death would not be included in the taxpayer's gross estate under §§ 2042 or 2035.…
IRS determination 200947069: Five-year extension for amortizing an unfunded pension liability
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to the plan's amortization charge bases identified in its application…
IRS determination 200947068: Five-year extension for amortizing an unfunded pension liability
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to the plan's amortization charge bases identified in its application…
IRS determination 200947067: Five-year extension for amortizing an unfunded pension liability
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applies to the plan's amortization charge bases identified in its application…
IRS determination 200947066: Six-year extension for amortizing an unfunded pension liability
The IRS approved a plan's request for a six-year automatic extension to amortize unfunded liabilities. The extension applies to the plan's amortization charge bases identified in its application and…
CCA 200947063: Disclosure of tax information during a nontax-crime investigation
Chief Counsel advice considered whether federal officers could obtain tax information under § 6103(i) while investigating or prosecuting a nontax crime. The advice states that the provision implies…
CCA 200947062: Contribution date for property transferred to charity after acquisition
Chief Counsel advice addressed when a charitable contribution occurs if a donor purports to transfer property before receiving title to it. If state law treats the donor as transferring title to the…
CCA 200947061: National Office review of Internet-provider search warrants
This one-page Chief Counsel advice concerns search warrants directed to Internet providers. In response to a forwarded question, the writer states that the National Office does not need to see…
CCA 200947060: Email as a potentially disclosable Jenks Act document
This Chief Counsel advice concerns documents related to the Jenks Act. The writer reports that the IRS has not produced documents regarding the Act and states that an email could be considered a…
CCA 200947059: Insurance salesperson independent-contractor questions
This Chief Counsel advice discusses notices concerning whether insurance salespersons are independent contractors. The writer says the substance of the notices appears in the Internal Revenue Manual…
CCA 200947058: Federal employment status during transfer to an international organization
This Chief Counsel advice discusses whether a federal employee remained a United States employee after being transferred to NATO. It summarizes Adair v. Commissioner, T.C. Memo. 1995-493, in which…
CCA 200947057: Corrected case name and additional theories for a conservation contribution
This Chief Counsel advice corrects a previously supplied case name, stating that the correct name is Cooley rather than Dooley. It gives the citation as 33 T.C. 223, 225 (1959), which concerns a…
CCA 200947056: Principal-residence factors for the first-time homebuyer credit
This Chief Counsel advice responds to questions from the Baltimore Sun. It says the first question was primarily a gift-tax question and that a redacted office has jurisdiction over gift tax. 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.