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 200931020: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931019: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931018: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931017: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931016: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931015: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931014: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931013: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931012: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200931011: Husband and Wife receive more time to allocate GST exemptions
The IRS granted Husband and Wife an additional 60 days to allocate their generation-skipping transfer tax exemptions to earlier transfers to an irrevocable trust. Their attorney had reported the…
PLR 200931010: Taxpayer receives more time to allocate a GST exemption
The IRS granted a taxpayer an additional 60 days to allocate a generation-skipping transfer tax exemption to a prior transfer to Trust B. The taxpayer's accounting firm had advised that…
PLR 200931009: More time granted for a GST exemption allocation, with zero inclusion ratios for successor trusts
The IRS granted a taxpayer 60 additional days to allocate GST exemption to an insurance-policy transfer to Trust 2. The taxpayer's accountant had reported the transfer but did not reflect prior GST…
PLR 200931008: Commodity-linked notes and foreign subsidiary income qualify for RIC gross-income test
The IRS ruled that income and gain from four specified commodity-linked notes would be qualifying income for a regulated investment company under section 851(b)(2). The notes were linked to…
CCA 200931007: Nuclear component removal costs and specified liability losses
This Chief Counsel memorandum addresses whether costs to remove and replace nuclear power plant components qualify as nuclear decommissioning costs and whether the costs can produce specified…
PLR 200931006: Corporation receives more time to make an S election
The IRS determined that a corporation had reasonable cause for failing to timely elect S-corporation status. The corporation was incorporated in the state identified in the ruling and intended the…
PLR 200931005: Late Form 1128 treated as timely for an accounting-period change
The IRS granted relief for a corporation's late Form 1128, treating the application as timely filed for a requested change from a June 30 tax year to a December 31 tax year. The corporation had…
PLR 200931004: Internal distribution and split-off approved as a divisive reorganization
The IRS approved a proposed transaction separating two business operations within an affiliated corporate group. A subsidiary would receive one business in exchange for its stock, that stock would…
PLR 200931003: Commodity-linked notes and foreign subsidiary income qualify as RIC income
The IRS ruled that income and gain from four specified commodity-linked notes would be qualifying income for a regulated investment company under section 851(b)(2). The notes were linked to…
PLR 200931002: Purchaser receives more time to make a section 338(g) election
The IRS granted a foreign purchaser an extension of time to file a section 338(g) election for its acquisition of a target corporation and the deemed acquisitions of three target subsidiaries. The…
PLR 200931001: Taxpayers may revoke election out of installment method after preparer misinformation
The IRS allowed taxpayers to revoke their election out of the installment sale method for a prior sale of their principal residence. Their first return preparer incorrectly advised that installment…
IRS determination 200930055: Organization’s section 501(c)(3) exemption revoked for private benefit
The IRS issued a final adverse determination revoking an organization’s section 501(c)(3) tax exemption, effective on a redacted date. The examination report says the organization served private…
PLR 200930054: IRS grants a conditional minimum funding standard waiver
The IRS granted a company a conditional waiver of the minimum funding standard for an employee pension plan. The company had experienced a major decrease in its aircraft maintenance and modification…
PLR 200930053: Makeup distribution will not modify substantially equal IRA payments
The IRS ruled that an IRA custodian’s failure to distribute enough to cover state tax withholding, followed by a proposed makeup distribution, would not modify the taxpayer’s series of substantially…
PLR 200930052: IRS waives 60-day rollover deadline when 60th day fell on Sunday
The IRS waived the 60-day deadline for a partial IRA rollover. The taxpayer decided to roll over part of a distribution on the 59th day, but the 60th day fell on a Sunday, and the deposit into a new…
PLR 200930051: IRS waives rollover deadline after military separation and medical emergencies
The IRS waived the 60-day rollover requirement for a taxable distribution from a military participant loan. After separating from active duty, the taxpayer learned that the outstanding loan balance…
PLR 200930050: IRS waives IRA rollover deadline after financial institution error
The IRS waived the 60-day rollover requirement for a taxpayer who moved IRA funds into a non-IRA account after relying on advice from a financial institution. The taxpayer intended to complete the…
IRS determination 200930049: Exemption denied to community recreation organization
The IRS denied an organization’s application for recognition under section 501(c)(3). The organization proposed community events, recreation, tree planting, street cleaning, fundraising sales, and…
CCA 200930047: Notice to indirect partners may not be required in certain circumstances
The Office of Chief Counsel advised that the IRS does not need to issue a notice of a proceeding to an indirect partner when it has already sent the notice to the pass-through partner responsible…
CCA 200930046: Tax matters partner designation after entity changes
The Office of Chief Counsel addressed questions about tax matters partner designations in TEFRA proceedings involving a limited partnership and a limited liability company. It advised that a TEFRA…
CCA 200930045: Non-member may not be designated as tax matters partner
The Office of Chief Counsel advised that an operating agreement’s designation of a non-member as tax matters partner was invalid. It said the designation on the return appeared proper because it…
CCA 200930044: Withdrawn timely protests allow prompt assessment after Appeals sustains liability
This Chief Counsel Advice addresses the effect of a responsible person's withdrawal of a timely protest against a proposed trust fund recovery penalty. It concludes that withdrawing the protest…
CCA 200930043: Partnership loss disallowance is a partnership item
This Chief Counsel Advice addresses the classification of a partnership loss disallowance. It concludes that the disallowance is a partnership item, regardless of the grounds for disallowance. It…
CCA 200930042: Unresolved AAR issues require a TEFRA proceeding for a final determination
This Chief Counsel Advice addresses the choices available when the IRS does not accept an amended administrative request without qualification. It states that the options are to accept the AAR or…
CCA 200930041: Duplicate notices may be appropriate when delivery to a TMP is uncertain
This Chief Counsel Advice addresses where to send notice of a partnership proceeding when the designated tax matters partner has a home address and the partnership or its trustee may have other…
CCA 200930040: Form 870-LT Part II is not needed to assess partnership penalties
This Chief Counsel Advice addresses the consequences of an unexecuted Part II of Form 870-LT, which concerns a partnership settlement. The advice states that the IRS generally has one year after…
CCA 200930039: Chief Counsel relays DOL view on fiduciary involvement in a prohibited transaction
This Chief Counsel Advice relays an informal Department of Labor view concerning a fiduciary's use of a retirement plan's investment in a mutual fund. The DOL view was that, unless the fiduciary…
CCA 200930038: Adequate consideration requires a good-faith fair-market valuation
This Chief Counsel Advice discusses the adequate-consideration exception to the prohibited-transaction rules for a plan's acquisition or sale of qualifying employer securities. It explains that the…
CCA 200930037: U.S. parent generally liable for employment taxes on earlier wages of foreign disregarded entity
This Chief Counsel Advice addresses employment taxes on wages paid to employees of a foreign entity treated as disregarded from its U.S. parent for earlier years. It states that the IRS could assert…
PLR 200930035: Cooperative payments qualified as per-unit retains and patronage dividends
The IRS ruled that a farmers’ cooperative’s cash advances to growers qualified as per-unit retain allocations paid in money, and that its cash final settlements qualified as patronage dividends paid…
PLR 200930034: Late S corporation election treated as timely for reasonable cause
The IRS ruled that a corporation could make a late S corporation election effective from the requested date because it established reasonable cause for not filing Form 2553 on time. The corporation…
PLR 200930033: Extension granted to elect out of automatic GST allocation for an insurance trust
The IRS granted a grantor an additional 60 days to elect out of the automatic allocation of generation-skipping transfer tax exemption to an irrevocable insurance trust for the grantor's sister. The…
PLR 200930032: Extension granted to allocate GST exemption to earlier trust transfers
The IRS granted two donors an additional 60 days to allocate their generation-skipping transfer tax exemptions to earlier transfers to a trust for their children and descendants. The donors had not…
PLR 200930031: Executor granted time to make QTIP and reverse QTIP elections
The IRS granted an estate executor an additional 60 days to make a qualified terminable interest property election and a reverse QTIP election for a trust. The estate tax return reported all of the…
PLR 200930030: Corporate liquidation, reorganization, and contribution rulings issued for an acquisition
The IRS addressed the federal income tax treatment of a multi-step acquisition and integration involving domestic and foreign subsidiaries. It ruled that two subsidiary liquidations qualified as…
PLR 200930029: Employee tool and training reimbursement plan qualified as accountable
The IRS ruled that an employer's plan to reimburse service technicians for qualifying tools, equipment, uniforms, supplies, training, and certification expenses satisfied the requirements for an…
PLR 200930028: Estate granted time to make alternate valuation election
The IRS granted an estate executor additional time to make an alternate valuation election under section 2032. The executor's estate tax return was filed within one year after its due date, but the…
PLR 200930027: S election restored after inadvertent passive-income termination
The IRS determined that a corporation's S election had terminated after it had accumulated earnings and profits and excessive passive investment income for three consecutive years. The IRS also…
PLR 200930026: Late S corporation election treated as timely for reasonable cause
The IRS ruled that a corporation's late S corporation election could be treated as timely because the corporation established reasonable cause for failing to file Form 2553 on time. The…
PLR 200930025: Acquisition merger and related transactions received federal tax rulings
The IRS ruled on the federal income tax consequences of a proposed downstream merger and related transactions involving a holding company, its subsidiaries, and an acquiring corporation. It…
PLR 200930024: Foreign entity granted time to elect disregarded status
The IRS granted a foreign eligible entity an additional 60 days to elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on its…
PLR 200930023: Foreign entity granted time to elect disregarded status
The IRS granted a foreign eligible entity an additional 60 days to elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election effective on its…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign entity formed as part of a restructuring intended to be treated as disregarded for federal tax purposes but did not timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from the…
IRS grants 60 days to make a late disregarded-entity election
A foreign eligible entity with a single owner intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted the entity 60 days from 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.