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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Determination 200925050: 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 April 1, 2008. The extension applied to the amortization charge bases identified in the…
Determination 200925049: Former participants may make tax-free rollovers into profit-sharing plan
A tax-exempt employer maintained a pension plan, a profit-sharing plan with a section 401(k) arrangement, and a section 403(b) plan. It asked whether former participants could move eligible…
Determination 200925048: IRA rollover waiver denied for lack of supporting evidence
A 63-year-old taxpayer withdrew funds from an IRA intending to find another IRA with a higher return but did not complete a rollover within 60 days. He argued that a foot injury prevented him from…
Determination 200925047: Widow receives waiver of retirement-plan rollover deadline
A widow received a distribution from her late husband's qualified retirement plan but did not roll it over within 60 days. During the rollover period, she was receiving treatment for depression…
Determination 200925046: Disabled taxpayer receives waiver for two IRA rollovers
A 61-year-old taxpayer withdrew funds from two IRAs after a bank representative incorrectly advised that no current income tax would be owed because of his disability. He deposited the funds in…
Determination 200925045: Taxpayer receives more time to undo five Roth IRA conversions
A taxpayer converted five traditional IRAs to Roth IRAs but later learned that his modified adjusted gross income exceeded the eligibility limit. He missed the deadline to recharacterize the…
Determination 200925044: Partial IRA transfer modifies substantially equal payment series
A 56-year-old taxpayer was taking substantially equal periodic payments from an IRA under the fixed amortization method. Acting on a financial adviser's guidance, she transferred part of that IRA,…
Determination 200925043: Waiver granted after adviser mistakenly closed inherited IRA
A widow inherited her husband's IRA and told her financial adviser that she wanted to treat it as her own, keep it open, and take small distributions as needed. She signed a form prepared by the…
CCA 200925042: Section 6109 permits but does not require ITINs for deceased individuals
This Chief Counsel Advice considers whether the IRS may issue an Individual Taxpayer Identification Number to a deceased applicant. A number may be needed to process tax benefits involving a…
CCA 200925041: A conditional divorce decree does not release a dependency exemption
This Chief Counsel Advice explains what a noncustodial parent must submit to claim a child’s dependency exemption under section 152(e). A divorce decree that permits the claim only when the parent…
PLR 200925040: Corporation received relief for a late S election
A corporation and its shareholders intended for the company to be treated as an S corporation beginning in a redacted year, but the election was not filed on time. The IRS found reasonable cause for…
PLR 200925039: Physical-injury settlement payments were excluded and not reportable
A qualified settlement fund was established to resolve personal physical injury claims arising from a redacted tort. It asked whether certain payments to claimants were excluded from their gross…
PLR 200925038: Foreign entity received more time to elect disregarded status
A foreign eligible entity wholly owned by another entity intended to be treated as disregarded from a redacted date. It inadvertently failed to file Form 8832 on time. The IRS found that the…
PLR 200925037: Foreign entity received more time to elect partnership status
A foreign eligible entity intended to elect partnership classification from the date it was formed. It inadvertently failed to file Form 8832 on time. The IRS concluded that the entity met the…
PLR 200925036: Service-based disability benefits were not excluded from income
A state asked whether disability retirement payments under its retirement plan were excluded from recipients’ income as workers’ compensation. The governing statute covered disabilities that were…
PLR 200925035: Corporation received relief for a late S election
A corporation’s shareholder intended for the company to be treated as an S corporation from a redacted date, but the election was not filed on time. The IRS found reasonable cause for the late…
PLR 200925034: Foreign entity received more time to elect disregarded status
A foreign eligible entity intended to be treated as a disregarded entity from the date it was formed. It did not file Form 8832 on time because of inadvertence. The IRS concluded that the entity met…
PLR 200925033: Foreign entity received more time to elect disregarded status
A foreign eligible entity intended to be treated as a disregarded entity from the date it was formed. It did not file Form 8832 on time because of inadvertence. The IRS concluded that the entity met…
PLR 200925032: Public retiree health trust’s income was excluded, but filing depended on classification
A state created a trust to fund post-employment medical benefits for public employees participating in its retirement plans. With proposed safeguards limiting participants and distributions to…
PLR 200925031: Corporation received relief after two QSSTs failed to distribute all income
Two trusts holding stock in an S corporation elected qualified subchapter S trust status but failed to distribute all of their income as required. The corporation’s S election therefore terminated.…
PLR 200925030: Extensions preserved branch-tax treatment of an internal stock transfer
A foreign corporate group transferred a domestic financial company’s stock to a newly formed domestic corporation as part of a restructuring. The foreign transferor and domestic transferee missed…
PLR 200925029: Option adjustments following a special distribution arose from a corporate transaction
A real estate investment trust made a special distribution after liquidating a subsidiary. The distribution was nonrecurring, related to a capital transaction, and potentially diluted the value of…
PLR 200925028: Estates received more time to allocate GST exemption to two trusts
A married couple created and funded separate trusts for each of their children and later descendants. Their accounting firm reported the gifts and elected gift splitting but failed to allocate…
PLR 200925027: Late ESBT elections did not end corporation’s S status
Seven trusts became shareholders of an S corporation, but elections for five of them to be treated as electing small business trusts were not valid or timely. Elections for the other two were…
PLR 200925026: Entity received more time to elect disregarded status
An eligible entity intended to elect disregarded status for federal tax purposes from a redacted date. Its Form 8832 was inadvertently not filed on time. The IRS concluded that the entity met the…
PLR 200925025: Entity received more time to elect disregarded status
An eligible entity intended to elect disregarded status for federal tax purposes from a redacted date. Its Form 8832 was inadvertently not filed on time. The IRS concluded that the entity met the…
PLR 200925024: Entity received more time to elect partnership status
An entity formed under state law was eligible to be treated as a partnership for federal tax purposes. It failed to file Form 8832 to elect that classification. The IRS concluded that the entity met…
PLR 200925023: Foreign entity received more time to elect partnership status
A foreign eligible entity intended to elect partnership treatment for federal tax purposes from a redacted date. It did not file Form 8832 on time. The IRS concluded that the entity met the…
PLR 200925022: Foreign entity received more time to elect disregarded status
A foreign company intended to be treated as an entity disregarded from its owner for federal tax purposes beginning on a redacted date. It failed to file Form 8832 on time because of inadvertence.…
PLR 200925021: Foreign entity received more time to elect disregarded status
A foreign company intended to be treated as an entity disregarded from its owner for federal tax purposes beginning on a redacted date. It failed to file Form 8832 on time because of inadvertence.…
PLR 200925020: Entity received more time to elect corporate tax status
A domestic eligible entity intended to be treated as an association taxable as a corporation beginning on a redacted date. It did not file Form 8832 on time because of inadvertence. The IRS…
PLR 200925019: Corporation received more time to make its IC-DISC election
A parent corporation formed a wholly owned subsidiary that was intended to elect interest charge domestic international sales corporation status. Its accountant prepared Form 4876-A and filing…
PLR 200925018: Estate received more time to allocate GST exemption to a trust
A decedent made two cash transfers in one year to an irrevocable trust for a brother and the brother's descendants. The decedent's gift tax return reported those transfers but did not allocate…
PLR 200925017: Trust received consent to revoke its ESBT election
A trust's trustee had elected to treat the trust as an electing small business trust effective on a redacted date. The trustee later asked the IRS to consent to revocation of that ESBT election as…
PLR 200925016: LLC received more time to elect corporate tax status
A wholly owned domestic limited liability company and its owner intended the company to be taxed as an association taxable as a corporation from its formation date. The company did not file its…
PLR 200925015: Estate received more time to allocate GST exemption to a trust
A decedent created an irrevocable trust for her children and their descendants and funded it with shares of closely held stock. Her gift tax return reported the transfer but did not allocate…
PLR 200925014: LLC received more time to elect corporate tax status
A domestic limited liability company was eligible to be treated as an association taxable as a corporation from its formation date. It did not file its entity-classification election on time. The…
PLR 200925013: Foreign entity received more time to elect disregarded status
A foreign entity became wholly owned by another foreign entity and intended to be treated as disregarded from its owner for federal tax purposes from the acquisition date. The election was not filed…
PLR 200925012: Foreign entity received more time to elect disregarded status
A foreign entity became wholly owned by another foreign entity and intended to be treated as disregarded from its owner for federal tax purposes from the acquisition date. The election was not filed…
PLR 200925011: Foreign entity received more time to elect disregarded status
A foreign entity was wholly owned by another foreign entity and intended to be treated as disregarded from its owner for federal tax purposes from its formation date. The election was not filed on…
PLR 200925010: Foreign entity received more time to elect disregarded status
A foreign entity was wholly owned by another foreign entity and intended to be treated as disregarded from its owner for federal tax purposes from its formation date. The election was not filed on…
PLR 200925009: Foreign entity received more time to elect disregarded status
A foreign entity was wholly owned by another entity and intended to be treated as disregarded from its owner for federal tax purposes from its formation date. The election was not filed on time,…
PLR 200925008: Estate received more time to split a marital trust for GST purposes
An estate made both a qualified terminable interest property election and a reverse QTIP election for a marital trust, then allocated less GST exemption than the amount funding the trust. The…
PLR 200925007: Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200925006: Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200925005: S election expenses qualified as recognized built-in losses
A cash-method personal service corporation planned to elect S corporation status while it had outstanding accounts receivable. It asked whether salaries, wages, payroll expenses, and accounts…
PLR 200925004: LLC received 90 more days to elect corporate tax status
A domestic limited liability company had partnership status by default but was eligible to elect treatment as an association taxable as a corporation. It did not file Form 8832 on time for the…
PLR 200925003: Split-dollar premiums avoided income and gift treatment under stated conditions
An irrevocable trust owned a life insurance policy on its creator under a split-dollar arrangement with a partnership. The IRS ruled that the partnership's premium payments would not produce income…
PLR 200925002: Liquidity facility did not undermine preferred stock's equity treatment
A closed-end regulated investment company planned to replace auction-rate preferred stock with variable-rate demand preferred stock backed by a bank liquidity facility. The bank could require…
PLR 200925001: Religious university's ministers qualified for housing-allowance treatment
A religious university asked the IRS to clarify an earlier ruling about housing allowances paid to ordained, commissioned, or licensed ministers serving as faculty or in management and…
Determination 200924063: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
PLR 200924062: Taxpayer received more time to reverse an ineligible Roth conversion
A taxpayer attempted to convert part of a traditional IRA to a Roth IRA after relying on a tax firm that failed to explain the deadline. The firm later treated the conversion as tax-free and did not…
PLR 200924061: Financial institution error excused a late retirement-plan rollover
After losing her job, a taxpayer directed her former employer's 401(k) plan to send a distribution to a financial institution for rollover to an IRA. The institution instead opened a taxable account…
Determination 200924060: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200924059: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200924058: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
PLR 200924057: Taxpayer received more time to complete an IRA rollover
An IRA owner withdrew a matured certificate of deposit intending to roll the money into another IRA, but did not complete the rollover within 60 days. During that period, she was caring for her…
PLR 200924056: Estate received more time to complete a decedent's IRA rollover
An IRA owner withdrew funds intending to complete a rollover, but severe medical problems, repeated hospitalizations, and resulting memory and hearing loss prevented him from meeting the 60-day…
Determination 200924055: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200924054: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on January 1, 2008. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
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.