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 200927006: Ineligible tiered trusts do not defeat intended S election
A corporation intended to elect S status, but family groups held its shares through trusts that were partly owned by other trusts rather than entirely by individuals. Those tiered arrangements made…
PLR 200927005: Foreign securities trader may make late mark-to-market election
A foreign entity had used section 475(f) mark-to-market accounting for securities while classified as a corporation. It later received permission to elect partnership status retroactively, which…
PLR 200927004: New parent receives extra time to elect consolidated return filing
A parent corporation and two subsidiaries became a new affiliated group when the former parent’s ownership dropped below the 80-percent affiliation threshold. The new group missed the deadline to…
PLR 200927003: Shareholder may make retroactive QEF election for foreign company
An individual bought stock in a foreign company but did not make a timely qualified electing fund election because a certified public accountant failed to identify the company as a passive foreign…
PLR 200927002: Asphalt production and wholesale marketing generate qualifying income
A publicly traded partnership operated refineries and terminals that produced straight-run asphalt and modified asphalt blended with non-petroleum additives. It sold these products to governments…
PLR 200927001: Corporation receives relief for late S election
A corporation intended to be taxed as an S corporation from a specified date, but the IRS did not timely receive its election. Section 1362(b)(5) permits a late election when reasonable cause…
IRS determination 200926049: Exemption denied because ministry funds benefited its founder
The IRS denied a ministry's application for exemption under section 501(c)(3). The ministry held worship services by telephone, operated from its founder's apartment, and paid the apartment rent and…
PLR 200926048: Scholarship procedures received advance approval
A private foundation asked the IRS to approve procedures for a scholarship program for graduating high school seniors. Applicants would submit essays, school officials would screen them for…
PLR 200926047: Scholarship program procedures received advance approval
A private foundation asked the IRS to approve procedures for scholarships supporting high school, college, or professional education. The foundation expected initially to award about 15 scholarships…
PLR 200926046: Scholarship grant procedures received advance approval
A private foundation asked the IRS to approve procedures for one or two annual scholarships, with preference for students pursuing medical, nursing, or related clinical education. A school…
PLR 200926045: Renewable scholarship procedures received advance approval
A private foundation asked the IRS to approve a renewable scholarship program for financially needy, academically qualified high school students. Eligible students would pursue health care careers,…
PLR 200926044: Medical and nursing scholarship procedures received advance approval
A private foundation asked the IRS to approve procedures for scholarships covering part or all of tuition for medical, nursing, and practical-nursing students in its service area. A grant and…
PLR 200926043: Trust scholarship procedures received advance approval
A testamentary trust asked the IRS to approve its procedures for renewable college scholarships. The program preferred young residents of a named community but allowed the selection committee…
PLR 200926042: Older taxpayers receive waiver for late IRA rollovers
Two older taxpayers requested a waiver of the 60-day deadline for rolling IRA distributions into new retirement accounts. They represented that serious medical conditions impaired their ability to…
PLR 200926041: Financial institution error supports late rollover waiver
A taxpayer asked the IRS to waive the 60-day deadline for rolling over part of a retirement-plan distribution. The taxpayer had requested a direct rollover while taking only after-tax contributions…
PLR 200926040: Surviving spouse receives waiver for late IRA rollover
A surviving spouse asked the IRS to waive the 60-day deadline for rolling over distributions from her deceased spouse's three IRAs. She relied on the deceased spouse's insurance agent and financial…
PLR 200926039: Bank error supports waiver for late IRA rollover
A taxpayer asked the IRS to waive the 60-day deadline for rolling an IRA distribution into another IRA. She instructed a second financial institution to open a rollover IRA certificate of deposit,…
PLR 200926038: Disaster scholarship program for employees' children approved
A corporate foundation asked the IRS to approve an employer-related scholarship program for the families of employees affected by qualified disasters. An independent public charity would administer…
IRS determination 200926037: Exemption denied for insider loans and private benefit
The IRS denied section 501(c)(3) exemption to an organization that conducted religious services and made interest-free loans. Its three board members were related, shared interests in related…
IRS determination 200926036: Hotel-integrated religious activities did not qualify for exemption
The IRS denied section 501(c)(3) exemption to an organization conducting religious services inside a for-profit resort hotel owned by a founder related to all three governing-body members. The hotel…
PLR 200926035: Two scholarship programs received advance approval
A foundation asked the IRS to approve two scholarship programs that it had operated before becoming a private foundation. One competitive program supported local high school graduates attending a…
PLR 200926034: Expanded four-year scholarship program approved
A private foundation asked the IRS to approve updated procedures for a scholarship program first approved in 1971. The revised program expected to award 200 to 500 scholarships, payable in equal…
IRS determination 200926033: Employer-linked hardship fund did not qualify for exemption
The IRS denied section 501(c)(3) exemption to a foundation created, controlled, and funded by a for-profit private security company. The foundation planned hardship grants of up to $300,000 for…
PLR 200926032: Matching-grant set-aside qualifies as a distribution
A private non-operating foundation asked the IRS to approve a set-aside for a matching grant to build accessible baseball and softball fields for children with physical and developmental…
PLR 200926031: Youth baseball scholarship procedures approved
A private foundation asked the IRS to approve scholarships for high school students from a metropolitan area who had participated in youth baseball or softball. Applicants had to be admitted to an…
PLR 200926030: Opera-program set-aside qualifies as a distribution
A private non-operating foundation asked the IRS to approve the unpaid balance of a multiyear pledge to an exempt opera company. The funds were intended to help the company meet the expenses of…
PLR 200926029: Employer-related merit scholarships approved
A private foundation asked the IRS to approve scholarships administered by an independent public charity through a national academic competition. The program primarily covered children and relatives…
PLR 200926028: Subsidiary receives relief for ineffective QSub election
An S corporation intended to elect qualified subchapter S subsidiary status for a subsidiary, but the election was ineffective because of procedural defects and because another person still held…
CCA 200926027: Built-in loss above section 382 limit must carry forward
A taxpayer planned to carry back recognized built-in losses exceeding its section 382 limitation after an ownership change. The taxpayer sought a private letter ruling allowing those losses to…
PLR 200926026: Corporation receives relief for late S election
A corporation and its two shareholders intended the corporation to be treated as an S corporation from its incorporation date, but the S election was not filed on time. The IRS found reasonable…
PLR 200926025: Statutory PILOT payments qualify as real property taxes
A developer planned a mixed-use condominium building on land leased from a public authority whose property was exempt from ordinary real property taxes. State law and the site lease required…
PLR 200926024: Business split-off qualifies for tax-free reorganization treatment
An S corporation proposed separating part of one business into a newly formed controlled corporation to resolve shareholder disputes and let different shareholder groups focus on different…
PLR 200926023: Leasehold-condominium PILOT payments are deductible taxes
A real estate developer leased tax-exempt land from a public-benefit corporation and planned to build and sell leasehold condominium units. The lease required payments in lieu of taxes, or PILOT,…
PLR 200926022: Historic rehabilitation qualifies for 50-percent lease exception
A partnership rehabilitating a historic building planned to lease it to government entities and asked how the tax-exempt-use-property rules affected its rehabilitation credit. The surrounding…
PLR 200926021: Estate receives extension for reverse QTIP elections
An estate allocated the decedent husband's generation-skipping transfer tax exemption to a QTIP trust but the return preparer failed to make the required reverse QTIP election. The estate also…
PLR 200926020: Later business combination does not invalidate earlier split-off rulings
Several taxpayers had received earlier rulings on the federal tax consequences of a corporate split-off and related transactions under sections 355 and 368. They later combined the controlled…
PLR 200926019: Later business combination does not invalidate earlier split-off rulings
Several taxpayers had received earlier rulings on the federal tax consequences of a corporate split-off and related transactions under sections 355 and 368. They later combined the controlled…
PLR 200926018: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926017: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926016: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926015: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926014: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926013: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926012: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926011: Foreign entity receives extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. It asked for additional time to make the entity-classification election…
PLR 200926010: Trust share may make retroactive QEF election
A separately taxed share of an irrevocable trust acquired an interest in a foreign corporation that was a passive foreign investment company. Its longtime CPA failed to identify the corporation as a…
PLR 200926009: Partnership may make retroactive QEF election
A general partnership received an interest in a foreign corporation that was a passive foreign investment company. Its longtime CPA failed to identify the corporation as a PFIC or advise the…
PLR 200926008: Trust share may make retroactive QEF election
A separately taxed share of an irrevocable trust acquired an interest in a foreign corporation that was a passive foreign investment company. Its longtime CPA failed to identify the corporation as a…
PLR 200926007: Foreign entity receives extension to elect disregarded status
A foreign company wholly owned by another entity was eligible to elect treatment as a disregarded entity but inadvertently failed to file Form 8832 on time. It asked for additional time to make the…
PLR 200926006: S corporation may make retroactive QEF election
An S corporation purchased stock in a foreign corporation that was a passive foreign investment company. Its longtime CPA failed to identify the corporation as a PFIC or advise it about a qualified…
PLR 200926005: Physician service agreements do not create private business use
A public authority had issued bonds to finance a nonprofit hospital facility, and the hospital proposed service agreements that paid physicians through percentages of adjusted patient billings,…
PLR 200926004: Foreign entity receives extension to elect disregarded status
A foreign company wholly owned by another entity was eligible to elect treatment as a disregarded entity but inadvertently failed to file Form 8832 on time. It asked for additional time to make the…
PLR 200926003: Foreign entity receives extension to elect disregarded status
A foreign company wholly owned by another entity was eligible to elect treatment as a disregarded entity but inadvertently failed to file Form 8832 on time. It asked for additional time to make the…
PLR 200926002: Corporation receives relief for late S election
A shareholder intended a newly incorporated company to be an S corporation from its incorporation date, but the company did not file its S election on time. The IRS found that the company had…
CCA 200926001: IRS may seize and sell vested executive stock options
A taxpayer held vested nonqualified and incentive stock options from a former employer when the IRS served a regular levy on the company. Chief Counsel advised that the options were property rights…
Determination 200925055: Five-year pension funding amortization extension approved
The IRS approved a five-year automatic extension for amortizing a pension plan's unfunded liabilities as of January 1, 2008. The extension applied to the amortization charge bases identified in the…
Determination 200925054: Five-year pension funding amortization extension approved
The IRS approved a five-year automatic extension for amortizing a pension plan's unfunded liabilities as of January 1, 2008. The extension applied to the amortization charge bases identified in the…
Determination 200925053: Five-year pension funding amortization extension approved
The IRS approved a five-year automatic extension for amortizing a pension plan's unfunded liabilities as of January 1, 2008. The extension applied to the amortization charge bases identified in the…
Determination 200925052: Five-year pension funding amortization extension approved
The IRS approved a five-year automatic extension for amortizing a pension plan's unfunded liabilities as of May 1, 2008. The extension applied to the amortization charge bases identified in the…
Determination 200925051: Pension funding amortization extension approved
The IRS approved an automatic extension for amortizing a pension plan's unfunded liabilities as of January 1, 2008. The extension applied to the amortization charge bases and periods identified in…
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.