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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CCA 200920038: Partnership adjustment claims would expire two years after filing if the IRS did nothing
Chief Counsel responded to an unclear question about whether the IRS should “pick up” a partnership return involving claims that might qualify as administrative adjustment requests under section…
PLR 200920037: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920036: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920035: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920034: Corporate group could adopt tax book value after the proposed acquisition
A domestic parent and its consolidated group had long used fair market value to apportion interest expense, which required costly inspections and valuations of U.S. and foreign assets. A foreign…
PLR 200920033: Proposed residence trust avoided section 2702 if QPRT conditions were met
A father had placed a residence in a qualified personal residence trust, retained a term interest, and transferred the remainder to his son when that term expired. The son proposed placing his…
PLR 200920032: Trust’s quick farmland sale did not trigger the related-party exchange rule
Three family trusts each held a one-third undivided interest in inherited farmland. They planned to exchange those interests for separate parcels of equal value so one trust could sell its parcel…
PLR 200920031: Grantor recognized gain when a CLAT paid its annuity with appreciated securities
A grantor charitable lead annuity trust owed a private foundation a fixed annual payment and proposed satisfying it with appreciated marketable securities. The trust was treated as owned by the…
PLR 200920030: Foreign entity received 60 days to file a late partnership election
A foreign eligible entity intended to elect partnership treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920029: Successor received 60 days to file the predecessor LLC’s corporate election
A successor asked for more time to file an entity-classification election for a predecessor limited liability company. The predecessor had inadvertently failed to file Form 8832 electing corporate…
PLR 200920028: Foreign entity received 60 days to file a late partnership election
A foreign eligible entity intended to elect partnership treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. A foreign eligible entity with multiple owners may…
PLR 200920027: Foreign entity received 60 days to file a late partnership election
A foreign eligible entity intended to elect partnership treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920026: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920025: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920024: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920023: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920022: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920021: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920020: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920019: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920018: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920017: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920016: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not timely file Form 8832. It requested extra time under the…
PLR 200920015: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920014: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920013: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920012: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920011: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920010: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920009: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920008: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920007: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920006: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920005: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920004: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920003: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920002: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
PLR 200920001: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity with one owner intended to elect disregarded-entity treatment for federal tax purposes as of a redacted date but did not make a timely election. The entity-classification…
Determination 200919072: Heavy public gaming income and member benefit cost a social club its exemption
A social club operated card-gaming activities involving the general public and used the proceeds to fund activities for its members. Its estimated nonmember use of facilities ranged from about 29…
PLR 200919071: Mistaking the 60-day rollover deadline for 90 days did not justify a waiver
An individual received an IRA distribution and intended to roll it into another IRA. He completed the deposit after the deadline because he mistakenly believed the rollover period was 90 days rather…
PLR 200919070: Adviser’s non-IRA deposit justified a rollover waiver
An individual instructed a financial institution to move an IRA annuity into an IRA invested in a certificate of deposit. A financial specialist incorrectly marked the application so the proceeds…
PLR 200919069: Adviser errors and impaired capacity justified waivers for three IRA distributions
An 83-year-old individual received distributions after a financial adviser recommended liquidating three annuities without explaining that they were IRAs or that other options were available. The…
PLR 200919068: Bank’s mistaken dishonor of a funded check justified rollover relief
An individual withdrew an amount from an IRA, returned part of it, and deposited a check for the remaining portion into the IRA within the 60-day period. The financial institution dishonored that…
PLR 200919067: Bank’s non-IRA account error justified rollover treatment for the corrected amount
An 83-year-old individual brought an IRA distribution check to a longtime local bank and asked to open a rollover IRA. The bank representative ignored that request and an attached warning about the…
PLR 200919066: Incorrect self-directed IRA instructions justified two rollover waivers
A married couple intended to move their respective IRA distributions into self-directed IRAs invested in a real-estate limited partnership. Two companies instructed them to endorse and deliver the…
PLR 200919065: Adviser’s non-IRA deposit of a beneficiary distribution justified rollover relief
A 64-year-old beneficiary requested an IRA distribution intending to roll it directly into her own IRA. The financial adviser who completed the paperwork instead deposited the amount into the…
PLR 200919064: Voluntary amended return justified late Roth IRA recharacterization relief
A taxpayer converted a traditional IRA to a Roth IRA based on a joint return that omitted income from a Schedule K-1. When the spouses later reported the omitted income on an amended return, their…
PLR 200919063: Financial institution error justified a late IRA rollover
A 77-year-old taxpayer withdrew funds from an IRA and immediately took the check to another financial institution to open an IRA certificate of deposit. The institution instead placed the entire…
PLR 200919062: Family medical crises justified a late IRA rollover
A taxpayer withdrew money from an IRA and deposited it in a nonqualified savings account while intending to establish a rollover IRA. During the 60-day rollover period, the taxpayer cared for a…
PLR 200919061: Jointly held certificate of deposit did not qualify for rollover relief
A taxpayer distributed part of an individual retirement annuity and used it to buy a certificate of deposit held jointly with a spouse. The taxpayer said he told the receiving institution that the…
PLR 200919060: Poetry fellowship and award procedures received advance approval
A private foundation asked the IRS to approve its procedures for fellowships, prizes, and awards supporting aspiring poetry writers. Expert selection committees would evaluate applicants on merit,…
PLR 200919059: Need-based scholarship procedures received advance approval
A private foundation proposed annual scholarships for students from high schools in a specified region. Selection would consider enrollment or intended enrollment, a minimum 3.0 grade point average,…
PLR 200919058: Local one-time scholarship procedures received advance approval
A private foundation proposed one-time scholarships for graduating high school students from a specified area who planned to attend college or pursue accredited trade or professional training.…
PLR 200919057: Endowment units avoided UBTI and qualified as capital assets
A state university system's governing board proposed issuing contractual units in its pooled endowment fund to a charitable remainder unitrust for which the board was trustee and sole charitable…
PLR 200919056: Endowment units avoided UBTI and qualified as capital assets
A state university system's governing board proposed issuing contractual units in its pooled endowment fund to a charitable remainder unitrust for which the board was trustee and sole charitable…
PLR 200919055: Endowment units avoided UBTI and qualified as capital assets
A state university system's governing board proposed issuing contractual units in its pooled endowment fund to a charitable remainder unitrust for which the board was trustee and sole charitable…
Determination 200919054: Foundation lost exemption for noncooperation and private benefit
The IRS revoked a private foundation's section 501(c)(3) exemption after it repeatedly failed to provide requested books and records or cooperate with an examination. The examination report also…
Determination 200919053: Commercial debt-settlement operation lost exemption
The IRS revoked the section 501(c)(3) status of an organization whose principal activity had become administering debt-settlement plans. New management acquired the inactive organization's shell and…
Determination 200919052: Public banquet business cost a social club its exemption
A tax-exempt social club advertised its banquet facility to the general public for weddings, receptions, reunions, catering, bar service, and other events. Nonmember sources produced 41 percent and…
Determination 200919051: Gross receipts disqualified a small mutual insurer
A mutual property insurer had long qualified under section 501(c)(15), but Congress replaced the former written-premiums ceiling with new gross-receipts and premium-percentage tests. The insurer…
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.