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.

42,150 determinations and counting · Newest release October 16, 2026
42,150 determinations

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PLR

PLR 200945016: Subsequent nuclear decommissioning fund transfer approved

The IRS approved a taxpayer's schedule of deduction amounts for a subsequent special transfer to a qualified nuclear decommissioning reserve fund and a revised schedule of ruling amounts. The…

200945016·November 6, 2009
Approved
PLR

PLR 200945015: Subsequent nuclear decommissioning fund transfer approved

The IRS approved a taxpayer's request for a schedule of deduction amounts for a subsequent special transfer to a qualified nuclear decommissioning reserve fund. It also approved a revised schedule…

200945015·November 6, 2009
Approved
PLR

PLR 200945014: Subsequent nuclear decommissioning fund transfer approved

The IRS approved a taxpayer's request for a schedule of deduction amounts for a subsequent special transfer to a qualified nuclear decommissioning reserve fund. It also approved a revised schedule…

200945014·November 6, 2009
Approved
PLR

PLR 200945013: Subsequent nuclear decommissioning fund transfer approved

The IRS approved a taxpayer's request for a schedule of deduction amounts for a subsequent special transfer to a qualified nuclear decommissioning reserve fund. It also approved a revised schedule…

200945013·November 6, 2009
Approved
PLR

PLR 200945012: S corporation election and subsidiary election relief approved

The IRS ruled that a corporation's S corporation election could be treated as effective after the corporation had two classes of stock, because the problem was inadvertent and the corporation took…

200945012·November 6, 2009
Approved
PLR

PLR 200945011: Inherited IRA division approved, separate-account treatment denied

The IRS approved a request to divide an inherited individual retirement account into two sub-IRAs for beneficiaries under a deceased spouse's will. The division would not be treated as a transfer…

200945011·November 6, 2009
Mixed outcome
PLR

PLR 200945010: Officers not covered employees after merger

The IRS ruled that the taxpayer's officers were not covered employees for a short taxable year ending after a merger. The taxpayer requested the ruling under § 162(m), which limits deductions for…

200945010·November 6, 2009
Approved
PLR

PLR 200945009: Principal financial officers not covered employees

The IRS ruled that two principal financial officers of a publicly held corporation were not covered employees for a specified tax year. The corporation requested the ruling under § 162(m), which…

200945009·November 6, 2009
Approved
PLR

PLR 200945008: Inadvertent S corporation election and QSub relief approved

The IRS granted relief for a potentially invalid S corporation election caused by the taxpayer having two classes of stock. The taxpayer had also elected to treat several subsidiaries as qualified…

200945008·November 6, 2009
Approved
PLR

PLR 200945007: Extension granted for success-based fee documentation

The IRS granted a taxpayer an extension of time to complete documentation for success-based fees paid in connection with a taxable stock acquisition. The documentation could support excluding part…

200945007·November 6, 2009
Approved
PLR

PLR 200945006: ADITC flow-through after asset sale violates normalization rules

The IRS ruled that a utility would violate the former investment tax credit normalization rules by directly or indirectly passing through its unamortized accumulated deferred investment tax credit…

200945006·November 6, 2009
Approved
PLR

PLR 200945005: Deferred-compensation check reportable when actually received

The IRS ruled that an individual was not in constructive receipt of a deferred-compensation disbursement check during Year 1. The check had arrived at a successor employer's office on December 31,…

200945005·November 6, 2009
Approved
PLR

PLR 200945004: Stock exchange and upstream merger receive nonrecognition treatment

The IRS ruled on the federal tax consequences of an exchange of a holding company's stock and a subsequent upstream merger. The stock acquisition qualified as a qualified stock purchase, and the IRS…

200945004·November 6, 2009
Approved
PLR

PLR 200945003: Extension granted for GST exemption allocation

The IRS granted a spouse a 60-day extension to allocate available generation-skipping transfer tax exemption to a transfer to an irrevocable trust. The extension was requested after a tax…

200945003·November 6, 2009
Approved
PLR

PLR 200945002: Extension granted for corporate classification election

The IRS granted an eligible entity a 60-day extension to file Form 8832 and elect to be classified as an association taxable as a corporation. The entity had intended to make the election by the…

200945002·November 6, 2009
Approved
PLR

PLR 200945001: Extension granted for partnership classification election

The IRS granted a foreign eligible entity a 60-day extension to file Form 8832 and elect to be treated as a partnership for U.S. income tax purposes. The entity had inadvertently failed to file the…

200945001·November 6, 2009
Approved
PLR

PLR 200944061: 60-day rollover requirement waived

The IRS waived the 60-day rollover requirement for an individual's distribution from an IRA. The taxpayer explained that medical conditions affecting the taxpayer and the taxpayer's husband, for…

200944061·October 30, 2009
Approved
PLR

PLR 200944060: 60-day rollover requirement waived

The IRS waived the 60-day rollover requirement for an individual's distribution from an IRA. The taxpayer stated that the distribution was not deposited into an IRA as instructed and that the amount…

200944060·October 30, 2009
Approved
PLR

PLR 200944059: Surviving spouse cannot roll over an IRA distribution controlled by a trust

The ruling concerns a surviving spouse who was the trustee and beneficiary of a trust named as beneficiary of her deceased husband's IRA. She sought to withdraw the entire IRA balance from the trust…

200944059·October 30, 2009
Denied
PLR

PLR 200944058: IRS waives the 60-day rollover deadline after a financial institution error

The ruling concerns a taxpayer who received funds from an IRA to purchase stock through a financial institution. Because of a misunderstanding with an employee, the stock was sent to the taxpayer…

200944058·October 30, 2009
Approved
PLR

PLR 200944057: IRS waives the rollover deadline for unused IRA funds after medical hardships

The ruling concerns a taxpayer who received an IRA distribution intending to roll the funds into another IRA. The taxpayer deposited the funds into a nonqualified account, used part for personal…

200944057·October 30, 2009
Approved
PLR

PLR 200944056: IRS waives the rollover deadline after mental illness and hospitalization

The ruling concerns a taxpayer who received an IRA distribution under a qualified domestic relations order and intended to roll it into an IRA in her own name. She initially selected a direct…

200944056·October 30, 2009
Approved
PLR

PLR 200944055: Board member compensation does not jeopardize a business league’s exemption

The ruling concerns a business league exempt under section 501(c)(6) that contracts with one of its board members for educational and hotline services. The organization uses a conflict-of-interest…

200944055·October 30, 2009
Approved
PLR

PLR 200944054: Scholarship grant program approved under § 4945(g)(1)

The ruling concerns a private foundation that proposed a scholarship program for academically qualified students in their first or second year at a university. Applicants must attend the university,…

200944054·October 30, 2009
Approved
DET

Determination 200944053: IRS denies exemption to a healthcare data organization serving member interests

The IRS issued a final adverse determination to an organization that planned to collect and analyze healthcare data for large employer and health-plan members. The organization intended to publish…

200944053·October 30, 2009
Denied
PLR

PLR 200944052: Five-year amortization extension approved for an underfunded pension plan

The Service approved a request for a five-year automatic extension to amortize a pension plan’s unfunded liabilities. The extension applies to the plan year beginning May 1, 2008 and to the…

200944052·October 30, 2009
Approved
CCA

CCA 200944051: Whether an inactive subsidiary can be disregarded as a corporation

This Chief Counsel advice considers whether an insolvent subsidiary that ended its operations and sold all of its assets could be disregarded as a corporation and treated as having liquidated. It…

200944051·October 30, 2009
Advice
CCA

CCA 200944050: Investments in an undercapitalized project do not qualify for the New Markets Credit

This Chief Counsel Advice considers whether a community development entity's equity investment and loan to a qualified active low-income community business were qualified low-income community…

200944050·October 30, 2009
Advice
CCA

CCA 200944049: Payments under new agreements were contingent on a change in control

This Chief Counsel Advice analyzes payments made to executives under redacted agreements after a change in ownership or control. The Advice concludes that the payments would not have been made…

200944049·October 30, 2009
Advice
CCA

CCA 200944048: IRS may accept assigned life-insurance benefits during an installment agreement

This Chief Counsel Advice considers whether the Service may accept an assignment of life-insurance death benefits from taxpayers who have an installment agreement covering their outstanding income…

200944048·October 30, 2009
Advice
CCA

CCA 200944047: Sharing a completed tax opinion may destroy privilege

This Chief Counsel Advice discusses whether a taxpayer's tax advice remained privileged after opinions were shared with law firms and accountants. The Advice states that the tax advice privilege is…

200944047·October 30, 2009
Advice
CCA

CCA 200944046: Tax Court cases on substantial compliance for charitable contributions

This Chief Counsel Advice provides a list of Tax Court cases involving IRC § 170 charitable-contribution substantiation and the substantial-compliance doctrine. The list identifies cases where the…

200944046·October 30, 2009
Advice
CCA

CCA 200944045: Substitute options may qualify for rollover treatment under section 409A

This Chief Counsel Advice considers whether outstanding executive options may be replaced with substitute options without disparate treatment under the deferred-compensation rules of IRC § 409A. The…

200944045·October 30, 2009
Advice
CCA

CCA 200944044: Stock-option exercise generally creates the wage event

This Chief Counsel Advice addresses when employment taxes apply to nonstatutory stock options. It states that the wage event generally occurs when the options are exercised, and that employment…

200944044·October 30, 2009
Advice
CCA

CCA 200944043: Facade easement cases need training under the post-PPA rules

This Chief Counsel Advice reports on a memorandum concerning a motion for summary judgment in a docketed case involving a facade easement donated in the second half of 2006. The Advice states that…

200944043·October 30, 2009
Advice
CCA

CCA 200944042: Fundraising expenses may count toward the section 4955 excise tax

This Chief Counsel Advice considers whether fundraising materials should be included when evaluating a potential political campaign intervention violation by an exempt organization. The Advice…

200944042·October 30, 2009
Advice
CCA

CCA 200944041: Bankruptcy does not discharge every individual tax debt

This Chief Counsel Advice includes an article explaining that bankruptcy does not eliminate every individual taxpayer's tax debt. It identifies three categories that generally remain…

200944041·October 30, 2009
Advice
CCA

CCA 200944040: CAP teams should avoid tax guidance on incomplete transactions

This Chief Counsel Advice addresses when Compliance Assurance Process teams may discuss tax information about prospective or incomplete transactions with taxpayers or their representatives. It…

200944040·October 30, 2009
Advice
CCA

CCA 200944039: A disregarded LLC's tax lien should name its sole owner

This Chief Counsel Advice considers a Notice of Federal Tax Lien filed against a single-member limited liability company that had not elected association classification. The Advice treats the…

200944039·October 30, 2009
Advice
CCA

CCA 200944038: A Form 1040X may qualify as an AAR in limited circumstances

This Chief Counsel Advice considers whether a taxpayer's Form 1040X may be treated as an amended administrative adjustment request for partnership items. It states that this treatment could arguably…

200944038·October 30, 2009
Advice
CCA

CCA 200944037: Mitigation provisions can supersede TEFRA filing requirements

This Chief Counsel Advice addresses the relationship between the mitigation provisions of IRC § 1311 and the TEFRA provisions of § 6227. It states that § 1311(a) allows an adjustment otherwise…

200944037·October 30, 2009
Advice
CCA

CCA 200944036: Owner TIN is unnecessary on the 668J estate-tax lien

This Chief Counsel Advice addresses taxpayer-identification numbers on Forms 668H and 668J used for estate-tax liens. It recommends attempting to obtain the TIN of a qualified heir for the 668H lien…

200944036·October 30, 2009
Advice
CCA

CCA 200944035: Misvaluation does not extend the limitations period under section 6501(e)(2)

This Chief Counsel Advice addresses whether an item must be entirely omitted to extend the period of limitations under IRC § 6501(e)(2). It agrees that a complete omission is required and that…

200944035·October 30, 2009
Advice
CCA

CCA 200944034: Form 56 alone does not prove a trustee's signing authority

This Chief Counsel Advice considers whether a trustee may rely on a Form 56 to sign a closing agreement for a trust. It states that a self-serving affidavit is insufficient and that Form 56 provides…

200944034·October 30, 2009
Advice
CCA

CCA 200944033: TEFRA notices to indirect partners require paper copies

This Chief Counsel Advice considers whether pass-through partners may send notices of partnership administrative proceedings electronically to indirect partners under IRC § 6223(h). It states that…

200944033·October 30, 2009
Advice
CCA

CCA 200944032: An unused credit elect is paid against the succeeding year's tax on its due date

This Chief Counsel Advice analyzes when an unused credit elect is treated as a payment against the succeeding year's income tax for purposes of deficiency interest. It explains that IRC §§…

200944032·October 30, 2009
Advice
CCA

CCA 200944031: Partnership-return items bind partners absent a TEFRA proceeding

This Chief Counsel Advice considers whether a partner is bound by a partnership item reported on the partnership return when the Service does not conduct a TEFRA proceeding for that return. It…

200944031·October 30, 2009
Advice
CCA

CCA 200944030: Conversion notice precedes a valid notice of deficiency for K-1 discrepancies

This Chief Counsel Advice addresses a taxpayer who filed a notice of inconsistent treatment concerning a Schedule K-1 discrepancy. It states that the Service may issue a valid statutory notice after…

200944030·October 30, 2009
Advice
CCA

CCA 200944029: A timely computational adjustment remains valid after an invalid notice

This Chief Counsel Advice addresses a directly assessable computational adjustment in the appropriate amount. It states that a timely assessment remains valid even if an invalid statutory notice was…

200944029·October 30, 2009
Advice
CCA

CCA 200944028: An invalid notice may leave a computational adjustment time-barred

This Chief Counsel Advice warns that a statutory notice does not suspend the period for assessing an inconsistently reported partnership item unless partner-level determinations are required. It…

200944028·October 30, 2009
Advice
CCA

CCA 200944027: Non-NRSA postdoctoral stipends are subject to FICA

This Chief Counsel Advice analyzes whether stipends paid to postdoctoral fellows by a state university are subject to Federal Insurance Contributions Act (FICA) taxes. It distinguishes National…

200944027·October 30, 2009
Advice
PLR

PLR 200944026: Multi-step corporate separation and external spin-off approved

The IRS ruled on a proposed separation of two businesses conducted through a publicly traded parent and many domestic and foreign subsidiaries. The plan used a series of subsidiary stock transfers,…

200944026·October 30, 2009
Approved
PLR

PLR 200944025: Late S corporation election allowed for reasonable cause

The IRS determined that a company had reasonable cause for failing to timely file its S corporation election. The company had intended to file Form 2553 for a stated effective date but did not file…

200944025·October 30, 2009
Approved
PLR

PLR 200944024: Late S corporation election allowed for reasonable cause

The IRS determined that a company had reasonable cause for failing to timely file its S corporation election. The company intended to file Form 2553 for a stated effective date but did not file the…

200944024·October 30, 2009
Approved
PLR

PLR 200944023: Late S corporation election allowed for reasonable cause

The IRS determined that a company had reasonable cause for failing to timely make an S corporation election. The company and its shareholders had reported income consistently with the intended S…

200944023·October 30, 2009
Approved
PLR

PLR 200944022: Extension granted for late consolidated return election

The IRS granted a parent company and its includible subsidiaries 60 days to make a late election to file a consolidated federal income tax return. The parent had acquired the stock of several…

200944022·October 30, 2009
Approved
PLR

PLR 200944021: Inadvertent S corporation termination relief granted

The IRS determined that a corporation's S corporation election terminated inadvertently when the sole beneficiary of a trust failed to make the required qualified subchapter S trust (QSST) election.…

200944021·October 30, 2009
Approved
PLR

PLR 200944020: Inadvertent S corporation termination relief granted

The IRS determined that a corporation's S corporation election terminated when shares were transferred to a trust whose sole beneficiary did not timely make a qualified subchapter S trust (QSST)…

200944020·October 30, 2009
Approved
PLR

PLR 200944019: Late S corporation election allowed for reasonable cause

The IRS determined that a company had reasonable cause for failing to timely make an S corporation election. The company's sole shareholder intended the company to be treated as an S corporation…

200944019·October 30, 2009
Approved
PLR

PLR 200944018: Inadvertent S corporation termination relief after disproportionate distributions

The IRS considered whether a corporation's disproportionate shareholder distributions may have terminated its S corporation election by creating a second class of stock. The corporation discovered…

200944018·October 30, 2009
Approved

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.