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
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PLR

PLR 200944017: Extension granted for GST evidence and automatic exemption allocation

The IRS granted an estate an additional 60 days to submit a qualified physician's certification or other evidence concerning the decedent's mental incompetence for generation-skipping transfer (GST)…

200944017·October 30, 2009
Approved
PLR

PLR 200944016: LLC employees excluded from faculty practice plan common-paymaster test

The IRS ruled that employees of a single-member LLC would not be counted as employees of its nonprofit parent when applying the 30 percent concurrent-employment test for common-paymaster treatment.…

200944016·October 30, 2009
Approved
PLR

PLR 200944015: Extension granted to file duplicate Form 3115

The IRS granted a partnership 45 days to file a signed duplicate copy of Form 3115 with the IRS national office. The partnership had timely filed the original form with its federal tax return to…

200944015·October 30, 2009
Approved
PLR

PLR 200944014: Permission granted to discontinue consolidated returns

The IRS permitted a parent corporation to discontinue filing consolidated federal income tax returns with its wholly owned subsidiary beginning with calendar year 2009. The parent and subsidiary…

200944014·October 30, 2009
Approved
PLR

PLR 200944013: Trust modifications preserve GST-tax-exempt status

The IRS ruled that proposed nonjudicial modifications to a testamentary trust would not cause the trust to lose its exemption from generation-skipping transfer (GST) tax. The trust was irrevocable…

200944013·October 30, 2009
Approved
PLR

PLR 200944012: Condemnation proceeds received when legal restrictions ended

The IRS ruled that a cash-basis taxpayer did not actually or constructively receive condemnation proceeds in the year a city deposited them with the state treasurer. Withdrawal would have waived the…

200944012·October 30, 2009
Approved
PLR

PLR 200944011: Global restructuring with multiple spin-offs approved

The IRS ruled on a global restructuring intended to realign the businesses of a foreign parent and its U.S. affiliated group. The plan included entity conversions, a merger of the U.S. parent into a…

200944011·October 30, 2009
Approved
PLR

PLR 200944010: Extension granted for late entity classification election

The IRS granted a limited liability company 60 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The company was eligible to make…

200944010·October 30, 2009
Approved
PLR

PLR 200944009: Extension granted for late GST exemption allocation

The IRS granted an executor 60 days to allocate a decedent's generation-skipping transfer (GST) tax exemption to a trust. The estate had timely filed Form 706 with extensions, but the accountant…

200944009·October 30, 2009
Approved
PLR

PLR 200944008: Extension granted for late disregarded-entity election

The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the classification to be…

200944008·October 30, 2009
Approved
PLR

PLR 200944007: Extension granted for late disregarded-entity election

The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the classification to be…

200944007·October 30, 2009
Approved
PLR

PLR 200944006: Extension granted for late partnership election

The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the partnership classification to be…

200944006·October 30, 2009
Approved
PLR

PLR 200944005: Extension granted for late partnership election

The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the partnership classification to be…

200944005·October 30, 2009
Approved
PLR

PLR 200944004: Extension granted for late GST exemption allocations

The IRS granted a husband and wife an additional 60 days to allocate their generation-skipping transfer (GST) tax exemptions to transfers they had made to an irrevocable trust. Their accountant had…

200944004·October 30, 2009
Approved
PLR

PLR 200944003: Extension granted for late GST exemption allocation

The IRS granted a donor 60 days to allocate available generation-skipping transfer (GST) tax exemption to a lifetime transfer to an irrevocable trust. The donor had hired an accountant to prepare…

200944003·October 30, 2009
Approved
PLR

PLR 200944002: Trust transfer treated as completed gift and excluded from gross estate

The IRS ruled that a grantor's transfer of cash to a proposed irrevocable trust would be a completed gift for federal gift tax purposes. The trust benefited the grantor, the grantor's spouse, and…

200944002·October 30, 2009
Approved
PLR

PLR 200944001: Extension granted for late disregarded-entity election

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's default classification was an association taxable as…

200944001·October 30, 2009
Approved
DET

IRS revokes organization’s section 501(c)(3) exemption

The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3), effective January 1, 2004. The IRS determined that the organization was not operated exclusively for charitable…

200943047·October 23, 2009
Revocation
PLR

PLR 200943046: Surviving spouse may roll over inherited IRA proceeds

The IRS ruled that a surviving spouse could roll over proceeds from an inherited IRA into an IRA maintained in the spouse's own name, even though the decedent had named a trust as the IRA…

200943046·October 23, 2009
Approved
DET

IRS approves five-year extension for pension-plan unfunded liabilities

The IRS approved a plan's request for a five-year automatic extension to amortize specified unfunded liabilities. The extension applied to amortization charge bases established as of the stated date…

200943045·October 23, 2009
Approved
PLR

PLR 200943044: IRA distribution method approved under § 72(t)

The IRS approved a method for calculating annual distributions from an IRA as a series of substantially equal periodic payments under IRC § 72(t)(2)(A)(iv). The distributions would be made from IRA…

200943044·October 23, 2009
Approved
PLR

PLR 200943043: 60-day IRA rollover requirement waived for financial-institution error

The IRS waived the 60-day rollover requirement for a taxpayer's IRA distribution after finding that an employee of the financial institution had mishandled the rollover paperwork. The taxpayer…

200943043·October 23, 2009
Approved
PLR

PLR 200943042: Lobbying-grant treatment rules for public charities

The IRS ruled on how a public charity may treat grants to other public charities when measuring lobbying expenditures under the § 501(h) expenditure test. It approved treating unrestricted…

200943042·October 23, 2009
Mixed outcome
DET

Scholarship grant procedures approved under IRC § 4945(g)

The IRS approved a private foundation's procedures for awarding about five scholarships to individuals who show a passion for their intended field of study. Eligible recipients would work or live in…

200943041·October 23, 2009
Approved
PLR

PLR 200943040: Scholarship grant procedures approved under § 4945(g)(1)

The IRS approved a private foundation's proposed two-stage scholarship program for high school students. The program would fund college preparation costs and, for students who enroll in an…

200943040·October 23, 2009
Approved
CCA

CCA 200943039: Treasury Offset Program payments support lien filings

This Chief Counsel Advice addresses a work stoppage involving federal tax lien filings and releases in a Pennsylvania county. The memorandum explains that payments sent through the Treasury Offset…

200943039·October 23, 2009
Advice
CCA

CCA 200943038: SIFL valuation may be used for employer-chartered aircraft

This Chief Counsel Advice addresses how an employer may value an employee's use of a piloted aircraft. It states that, under the described facts, the employer may use either the general valuation…

200943038·October 23, 2009
Advice
CCA

CCA 200943037: Inconsistent partner filing may resolve an omitted K-1 item

This Chief Counsel Advice considers a corporate partner's Schedule K-1 reporting of a dividends-received deduction item. The advice states that the partnership must separately state the portion of…

200943037·October 23, 2009
Advice
CCA

CCA 200943036: TEFRA partnership proceedings address a corporate partner's dividends-received deduction

This Chief Counsel Advice considers which dividend-related determinations must be made at the partnership level in a TEFRA proceeding. The advice states that the partnership must determine the…

200943036·October 23, 2009
Advice
CCA

CCA 200943035: Valid tax matters partner designations must follow the regulations

This Chief Counsel Advice comments on a proposed response concerning the designation of a partnership's tax matters partner. It states that a valid designation made outside the partnership return…

200943035·October 23, 2009
Advice
CCA

CCA 200943034: Rehabilitation credits reduce a façade easement deduction

This Chief Counsel Advice addresses the charitable contribution deduction for a façade easement when a rehabilitation credit was claimed for the building. It states that, if a rehabilitation credit…

200943034·October 23, 2009
Advice
CCA

CCA 200943033: Requirements for façade easement contributions

This Chief Counsel Advice reviews the requirements for deducting a charitable contribution of a façade easement. It explains that the easement must protect a certified historic structure, preserve…

200943033·October 23, 2009
Advice
CCA

CCA 200943032: Storage expenses may qualify within the moving period

This Chief Counsel Advice responds to a question about whether storage expenses qualify as moving expenses. The writer says the facts are incomplete but identifies storage as an important factor in…

200943032·October 23, 2009
Advice
CCA

CCA 200943031: Training outline covers timing of business deductions

This Chief Counsel Advice transmits a training outline on when a taxpayer may deduct fixed and determinable expenses. The outline covers the fact of liability, reasonable accuracy, economic…

200943031·October 23, 2009
Advice
CCA

CCA 200943030: LMSB managers may designate a consolidated-group substitute agent

This Chief Counsel Advice addresses the designation of a substitute agent for a consolidated group. It states that Delegation Order 4-45 authorizes Team Managers in LMSB, as to their respective…

200943030·October 23, 2009
Advice
CCA

CCA 200943029: Section 1603 grants affect energy credits and basis

This Chief Counsel Advice addresses grants under section 1603 of the American Recovery and Reinvestment Act. It states that a grant is not a tax credit and that receiving the grant is not taxable…

200943029·October 23, 2009
Advice
CCA

CCA 200943028: SBA ARC loan interest is not borrower income

This Chief Counsel Advice addresses interest paid by the Small Business Administration to a lender under the America’s Recovery Capital Loan Program. It concludes that a qualified small-business…

200943028·October 23, 2009
Advice
PLR

PLR 200943027: Late S corporation election relief granted for reasonable cause

The IRS granted a corporation relief for failing to timely file Form 2553 to elect S corporation status. Based on the submitted facts and representations, the IRS found reasonable cause for the late…

200943027·October 23, 2009
Approved
PLR

PLR 200943026: Wrongful-death settlement damages excludable under § 104(a)(2)

The IRS ruled that an estate's recovery for the wrongful death of a decedent was excludable from gross income under IRC § 104(a)(2), except for any interest received. The recovery arose under a…

200943026·October 23, 2009
Approved
PLR

PLR 200943025: Retiree-benefit trust income excluded under § 115

The IRS ruled that a trust established by a public electric utility to fund post-employment medical and death benefits for retirees had income excludable from gross income under IRC § 115(1). The…

200943025·October 23, 2009
Approved
PLR

PLR 200943024: Extension granted to make a disregarded-entity election

The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect to be disregarded as an entity separate from its owner. The entity had intended the election to be…

200943024·October 23, 2009
Approved
PLR

PLR 200943023: Extension granted to make a disregarded-entity election

The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect to be disregarded as an entity separate from its owner. The entity had intended the election to be…

200943023·October 23, 2009
Approved
PLR

PLR 200943022: Late S corporation election relief granted

The IRS granted a corporation relief after its shareholder failed to timely file the election to treat it as an S corporation. The IRS found reasonable cause for the failure and ruled that the…

200943022·October 23, 2009
Approved
PLR

PLR 200943021: Revised nuclear decommissioning fund schedule approved

The IRS approved a taxpayer's revised schedule of ruling amounts for a nuclear decommissioning reserve fund. The taxpayer owned an interest in a nuclear plant and updated its schedule after the…

200943021·October 23, 2009
Approved
PLR

PLR 200943020: Late S corporation election relief granted for reasonable cause

The IRS granted a corporation relief for failing to timely file its election to be treated as an S corporation. The corporation was incorporated under state law, and its shareholder intended the…

200943020·October 23, 2009
Approved
PLR

PLR 200943019: Split-up reorganization of an S corporation's rental properties approved

The IRS approved a proposed transaction that would divide a closely held S corporation's two-apartment rental business between two shareholders after an operating dispute and litigation. The…

200943019·October 23, 2009
Approved
PLR

PLR 200943018: Sixty-day extension granted for a late entity classification election

The IRS granted a limited extension to a limited partnership that intended to elect classification as an association taxable as a corporation. The entity had failed to timely file Form 8832 for that…

200943018·October 23, 2009
Approved
PLR

PLR 200943017: Sixty-day extension granted for a late entity classification election

The IRS granted a limited extension to a limited partnership that intended to elect classification as an association taxable as a corporation. The entity had failed to timely file Form 8832 for that…

200943017·October 23, 2009
Approved
PLR

PLR 200943016: Sixty-day extension granted for a late entity classification election

The IRS granted a limited extension to a limited partnership that intended to elect classification as an association taxable as a corporation. The entity had failed to timely file Form 8832 for that…

200943016·October 23, 2009
Approved
PLR

PLR 200943015: Sixty-day extension granted for a late entity classification election

The IRS granted a limited extension to a limited partnership that intended to elect classification as an association taxable as a corporation. The entity had failed to timely file Form 8832 for that…

200943015·October 23, 2009
Approved
PLR

PLR 200943014: Wrongful-death damages generally excludable, but interest taxable

The IRS ruled that amounts a survivor receives under a legislative settlement for the wrongful death of a family member are excludable from gross income under IRC § 104(a)(2), except for interest.…

200943014·October 23, 2009
Mixed outcome
PLR

PLR 200943013: Sixty-day extension granted for an LLC's entity classification election

The IRS granted a limited extension to a state limited liability company that intended to be treated as an association taxable as a corporation for federal tax purposes. The LLC's two members…

200943013·October 23, 2009
Approved
PLR

PLR 200943012: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943012·October 23, 2009
Approved
PLR

PLR 200943011: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943011·October 23, 2009
Approved
PLR

PLR 200943010: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943010·October 23, 2009
Approved
PLR

PLR 200943009: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943009·October 23, 2009
Approved
PLR

PLR 200943008: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943008·October 23, 2009
Approved
PLR

PLR 200943007: Sixty-day extension granted for a foreign entity's partnership election

The IRS granted a foreign eligible entity an extension to elect partnership classification for federal tax purposes. The entity intended the classification to be effective on a specified date but,…

200943007·October 23, 2009
Approved
PLR

PLR 200943006: Sixty-day extension granted for a foreign entity's disregarded-entity election

The IRS granted a foreign eligible entity with one owner an extension to elect disregarded-entity classification for federal tax purposes. The entity intended that classification to be effective on…

200943006·October 23, 2009
Approved
PLR

PLR 200943005: Sixty-day extension granted for a foreign entity's disregarded-entity election

The IRS granted a foreign eligible entity with one owner an extension to elect disregarded-entity classification for federal tax purposes. The entity intended that classification to be effective on…

200943005·October 23, 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.