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 200924053: 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 200924052: 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…
CCA 200924051: Corporation named in a third-party summons was entitled to notice
Chief Counsel considered whether a corporate taxpayer had to receive notice of summonses that named both the corporation and one of its officers. Section 7609 gives notice rights to any person…
CCA 200924050: Defense contractor tax details required consent before IRS disclosure
Chief Counsel addressed whether the IRS could give procurement officials tax information about defense contractors subject to a Federal Acquisition Regulation self-certification requirement. The…
CCA 200924049: End of bankruptcy stay allowed tax deadlines to be calculated
Chief Counsel addressed how the automatic stay ends in a serial bankruptcy filing. It interpreted Bankruptcy Code section 362(c)(3)(A) as also lifting the stay that section 362(a)(8) places on…
CCA 200924048: Separate disclosure order was needed for additional criminal statutes
Chief Counsel considered whether tax returns obtained under a section 6103(i) order could be shared for investigations involving criminal statutes beyond the one identified in that order. The…
CCA 200924047: Bankruptcy stay continued for notice-of-deficiency deadlines
Chief Counsel considered whether the automatic stay ended under Bankruptcy Code section 362(c)(3)(A) for deadlines tied to a statutory notice of deficiency issued before a debtor's first Chapter 13…
CCA 200924046: Retirement-plan transfer could not be completed as a rollover
Chief Counsel gave a preliminary view that a proposed transaction involving money in a defined contribution plan and funding obligations of a defined benefit plan could not be completed as a…
CCA 200924045: Section 6662A penalty did not require participation in a listed transaction
Chief Counsel addressed language for asserting the section 6662A penalty in a statutory notice of deficiency involving a DATS transaction. It advised that participation in a listed transaction was…
CCA 200924044: Tax liens did not attach to a terminated LLC membership interest
Chief Counsel considered whether federal tax liens attached to a deceased taxpayer's former interest in a Kentucky limited liability company. State law determines what property rights existed when a…
CCA 200924043: Subsidiary took deferred distribution loss into account on parent's LLC conversion
A subsidiary distributed all interests in a disregarded entity to its parent and recognized a loss that was deferred under section 267(f) and the consolidated-return rules. The parent later…
CCA 200924042: Parent's earlier income did not increase a subsidiary's SRLY loss limit
A subsidiary brought separate-return-year net operating losses into a consolidated group and later was deemed liquidated into the group's parent after a section 338(h)(10) election. The parent…
CCA 200924041: Extraordinary dividend reduced basis in redeemed and retained shares
A corporate shareholder received non-pro-rata stock-redemption proceeds that were treated as a dividend under section 301 rather than as sale proceeds. It claimed a dividends-received deduction,…
PLR 200924040: Software license fees were active receipts rather than royalties
A corporate group sought ordinary-loss treatment for worthless stock in a software-development subsidiary. Section 165(g)(3) requires more than 90 percent of an affiliated subsidiary's lifetime…
PLR 200924039: Corporation received relief for a late S election
A corporation intended to be treated as an S corporation from its formation date but did not file the election on time. The IRS found reasonable cause for the late filing and granted relief under…
PLR 200924038: Nuclear plant owner received a special-transfer deduction schedule
A corporate owner of part of a nuclear plant requested a deduction schedule for a special transfer to its qualified nuclear decommissioning fund. Section 468A(f) permits a fund to receive…
PLR 200924037: Nuclear plant owner received a special-transfer deduction schedule
A corporate owner of part of a nuclear plant requested a deduction schedule for a special transfer to its qualified nuclear decommissioning fund. Section 468A(f) permits a fund to receive…
PLR 200924036: Foreign demerger qualified as a tax-free reorganization and distribution
A foreign corporation separated two active businesses through a demerger under its home-country law. It transferred one business and its related liabilities to a wholly owned corporation, which…
PLR 200924035: Public-entity reinsurer's income qualified for section 115 exclusion
A captive insurance company provided reinsurance only for municipalities, public authorities, and other public entities participating in two government-related insurance funds. Its premiums and…
PLR 200924034: Asbestos trust qualified as a settlement fund with deductible payments
A company in Chapter 11 planned to fund a court-supervised trust with cash and a note to resolve asbestos-related personal-injury claims. The IRS ruled that the trust would qualify as a settlement…
PLR 200924033: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924032: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924031: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924030: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924029: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924028: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924027: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924026: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924025: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924024: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924023: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924022: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924021: Split-dollar borrower received more time to file a loan representation
An employee participated in a tax-exempt employer's split-dollar life insurance plan and borrowed premium payments on a nonrecourse basis. The plan administrator failed to advise the parties that…
PLR 200924020: Corporation received relief for a late S election
A corporation intended to be treated as an S corporation from its incorporation date, but the IRS did not timely receive its Form 2553 election. The IRS found reasonable cause for the late election…
PLR 200924019: Employment agreement did not create a second class of stock
An S corporation had an informal, unwritten employment agreement with two officers and employees. All shares carried identical distribution and liquidation rights, and shareholder distributions had…
PLR 200924018: Trust consolidations caused no gain and preserved GST protection
A court approved consolidating three older irrevocable family trusts with three later trusts for the same grandchildren, subject to a favorable IRS ruling. Each combined trust would keep separate…
PLR 200924017: Corporation received relief for a late S election
A corporation's shareholder intended the company to be treated as an S corporation from its incorporation date, but the election was inadvertently not filed. The IRS found reasonable cause for the…
PLR 200924016: Mortgage trust received more time to elect REMIC status
A mortgage securitization trust agreement called for a master REMIC and a subsidiary REMIC. The return preparer received only a preliminary agreement that showed the master REMIC, so no Form 1066 or…
PLR 200924015: Public retiree health trust's income qualified for section 115 exclusion
A state created a trust to prefund medical and prescription benefits for retired public employees and their eligible family members. The trust's assets and income were dedicated to benefits and…
PLR 200924014: Partnership received more time to make a section 754 election
A limited partnership timely filed its return for the year in which a partner died, but inadvertently omitted an election under section 754. That election permits basis adjustments to partnership…
PLR 200924013: City could reallocate bond proceeds from stadium to park costs
A city originally traced tax-exempt bond proceeds to a sports facility that it later wanted to use for sponsorships and other private-business opportunities. It issued taxable bonds for a park…
PLR 200924012: Foreign entity received more time to elect corporate classification
A foreign eligible entity intended to be classified as an association taxable as a corporation from its formation date, but did not timely file Form 8832. The IRS found that the entity met the…
PLR 200924011: Entity received more time to elect partnership classification
A domestic eligible entity intended to be classified as a partnership from its formation date, but did not timely file the election. The IRS found that the entity met the standards for discretionary…
PLR 200924010: Foreign entity received more time to elect disregarded status
A foreign eligible entity wholly owned by one company intended to be disregarded as separate from its owner from a specified date. It inadvertently failed to file Form 8832 on time. The IRS found…
PLR 200924009: Corporation received inadvertent S termination relief after trust transfer
An S corporation shareholder transferred some stock to a trust that was not an eligible S corporation shareholder, terminating the company's S election. The company and its shareholders did not…
PLR 200924008: Trust decantings preserved GST exemption and caused no taxable gifts
A pre-1985 irrevocable family trust had been divided into six separate trusts, one for each of five grandchildren and one child. The trustees proposed moving each trust's principal to a new trust…
PLR 200924007: Spouses received more time to allocate GST exemption to family trusts
A married couple made transfers over eight years to separate trusts for their son and daughter. They timely filed gift tax returns and elected gift splitting, but did not allocate available…
PLR 200924006: Estate reporting errors did not prevent zero GST inclusion ratios
A decedent's will divided the estate residue among a descendants' trust and two marital trusts, but the estate tax return reported incorrect funding amounts. The executor made QTIP and reverse-QTIP…
PLR 200924005: Tax-exempt employer's deferred compensation plan qualified under section 457(b)
A section 501(c)(3) organization established a deferred compensation plan for selected managers and highly compensated employees. The plan limited deferrals, allowed a final-three-year catch-up,…
PLR 200924004: Corporation received relief for a late S election
A corporation intended to elect S corporation treatment from its incorporation date but did not timely file Form 2553. The IRS found reasonable cause for the late filing and granted relief under…
PLR 200924003: Corporation received relief for a late S election
A corporation's shareholder intended the company to be treated as an S corporation from a specified date, but the election was not filed on time. The IRS found reasonable cause for the late filing…
PLR 200924002: Foreign central bank qualified for section 892 exemption
A foreign central bank issued the country's currency, carried out monetary policy, managed reserves, and performed other central-bank functions under national law. Government bodies appointed its…
PLR 200924001: Corporation received relief for a late S election
A corporation's shareholder intended the company to be treated as an S corporation from its incorporation date, but the election was not filed on time. The IRS found reasonable cause for the late…
Determination 200923055: 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 200923060: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities identified in its application. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200923059: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities identified in its application. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200923058: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities identified in its application. The plan submitted an actuary's certification that it otherwise would face an accumulated funding…
Determination 200923057: Airline's late ten-year funding election was treated as timely
A commercial passenger airline planned to elect the Pension Protection Act's special ten-year amortization period for its pension plan's shortfall base. The statutory deadline was December 31, 2007,…
PLR 200923056: Financial institution error justified an IRA rollover waiver
An IRA owner transferred a distribution to a financial institution but it was placed in a non-IRA account. The institution knew the money came from an IRA, yet its representatives dissuaded the…
Determination 200923054: Pension plan received a five-year funding extension
A pension plan requested more time to amortize unfunded liabilities that existed on February 1, 2009. The plan submitted an actuary's certification that it otherwise would face an accumulated…
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.