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 200903100: Mathematics prizes were not taxable expenditures
A private operating foundation proposed monetary prizes for people who solved specified long-standing mathematical problems. A solution had to appear in a mathematics journal of worldwide repute and…
PLR 200903099: Employee-children scholarship program received advance approval
A private foundation proposed one academic and one technical scholarship each year for dependent children of a company's nonexecutive, full-time employees. An independent committee would choose…
PLR 200903098: Independently administered employee-children scholarships were approved
A private foundation proposed funding a public charity to administer scholarships for dependent children of a company's employees. The charity would independently select recipients using academic…
PLR 200903097: Christian ministry education grants received advance approval
A private foundation proposed grants for tuition, travel, room and board, and related costs of preparing for full-time Christian ministry or seminary teaching. Applicants generally had to pursue…
PLR 200903096: Statewide academic and service scholarships received advance approval
A private foundation proposed one to five annual scholarships for college-eligible state residents with strong academic records, community involvement, and financial need. Applicants had to submit…
Other 200903095: Charity lost exemption after failing to provide required information
The IRS revoked an organization's section 501(c)(3) status after it failed to respond to requests to file a Form 990 and provide information needed to examine its continued exemption. The…
Other 200903094: Small insurer lost exemption after failing the premium-receipts test
A controlled foreign corporation elected domestic tax treatment and had previously received recognition as a tax-exempt small insurance company under section 501(c)(15). It later stopped accepting…
Other 200903093: Run-off reinsurer lost exemption under the premium-receipts test
A controlled foreign corporation elected domestic tax treatment and had been recognized as a tax-exempt small insurance company under section 501(c)(15). The company reinsured…
Other 200903092: Inactive organization lost exemption after ignoring record requests
An organization had not filed an information return since a redacted year, and a state attorney general's website indicated that it no longer existed. The IRS wrote to the last known officer asking…
Other 200903091: Exemption revoked after years of missing Form 990 returns
An organization recognized under section 501(c)(3) had not filed Form 990 since a redacted year. The IRS requested two later returns through a written information document request, but the…
Other 200903090: Dissolved organization lost exemption after failing to document its assets
A section 501(c)(3) organization had been administratively dissolved by its state and had stopped filing Form 990. Its former president told the IRS that operations had ended and assets had gone to…
Other 200903089: Reinsurer lost exemption but retained its protective small-insurer election
A family-owned reinsurer affiliated with automobile dealerships stopped accepting new business and entered voluntary run-off. In the examined years it received no premium income, so premiums were…
Other 200903088: Private foundation lost exemption after ignoring repeated examination requests
A social-services organization had been recognized under section 501(c)(3) and was later classified as a private nonoperating foundation. The IRS had no record of required returns after a redacted…
Other 200903087: Organization lost exemption after failing to file a return or document its operations
A charitable organization failed to file its Form 990 for a redacted tax period. It also did not provide records showing that it had terminated, despite repeated letters and telephone messages from…
Other 200903086: Social-welfare organization lost exemption after failing to file or provide records
A social-welfare organization did not file Form 990 for a redacted tax period or answer the IRS's requests for information. It also did not provide books and records showing that its purposes and…
Other 200903085: Defunct charity lost exemption after failing to file a final return or produce records
A public charity told the IRS that it had stopped operating, but it had not formally dissolved. Payroll filings and prior assets indicated that it remained subject to a Form 990 filing requirement,…
Other 200903084: Inactive charity lost exemption after ignoring examination requests
A charity could not be located and appeared to have stopped operating. It did not respond to repeated appointment letters or provide information about its activities and finances for examination.…
Other 200903083: Dormant charity lost exemption because it never conducted exempt activities
A charity was unable to obtain grant funding and stopped operating soon after receiving exemption. Its former board member told the IRS that it never conducted exempt activities, received income,…
Other 200903082: Funeral insurance association lost exemption because premiums were too small a share of receipts
A mutual funeral service association collected policyholder assessments, invested reserves, and paid funeral and burial benefits. Its gross receipts stayed below the statutory ceilings for small…
Other 200903081: Supporting organization lost exemption after providing no support and benefiting private interests
A supporting organization was formed to hold a donated note receivable, invest its funds, and use the earnings or principal for a named charity. It received small payments on the note but never…
Other 200903080: Political organization denied social-welfare exemption because campaign intervention was its primary activity
A state affiliate of a national advocacy organization sought exemption as a social-welfare organization under section 501(c)(4). It trained precinct activists, identified and mobilized voters,…
TAM 200903079: Government contractor had to accrue unbilled service revenue as it was earned or became due
An accrual-method government contractor deferred revenue from fixed-price, cost-plus, and time-and-materials service contracts until final inspection and approval. The IRS concluded that severable…
PLR 200903078: S corporation shareholders could replace the simplified look-back method with the actual method
Shareholders of an S corporation had elected the simplified marginal impact method to calculate look-back interest on their shares of long-term contract income and expense. They asked to revoke that…
PLR 200903077: S corporation shareholders could replace the simplified look-back method with the actual method
Shareholders of an S corporation had elected the simplified marginal impact method to calculate look-back interest on their shares of long-term contract income and expense. They asked to revoke that…
PLR 200903076: S corporation shareholder could replace the simplified look-back method with the actual method
An S corporation shareholder had elected the simplified marginal impact method to calculate look-back interest on her share of long-term contract income and expense. She asked to revoke that…
PLR 200903075: S corporation could complete a tax-free divisive reorganization and spin-off
An S corporation operated two active businesses and wanted to separate one business so it could escape regulatory restrictions and enter a joint venture. Its subsidiaries would convert to…
PLR 200903074: Corporation received 60 days to file its intended late S election
A corporation’s shareholder intended the company to be an S corporation from its incorporation date, but Form 2553 was not filed on time. The company asked the IRS to treat its election as timely…
PLR 200903073: Insurance bad-faith settlement retained the character of the underlying injury damages
A highway worker became quadriplegic after a drunk driver struck him and obtained a judgment containing both compensatory and punitive damages. The defendants assigned him their bad-faith claim…
PLR 200903072: Parties received 60 days to make late foreign real-property statements and notices
A corporate group separated entities into publicly traded companies through transactions involving U.S. corporations or U.S. assets. The parties represented that shares of specified target…
PLR 200903071: LLC received 60 days to file its intended late S election
A limited liability company elected to be treated as a corporation, and its two members also intended S corporation status from the same effective date. Form 2553 was not filed on time. The IRS…
PLR 200903070: Subsidiaries were treated as joining a consolidated return despite missing Forms 1122
A parent corporation acquired two domestic subsidiaries and filed a consolidated federal return for the group, but the subsidiaries inadvertently omitted Forms 1122 consenting to the consolidated…
PLR 200903069: Partnership received 60 days to make a late section 754 election
A limited liability company treated as a partnership had a member die during the tax year. The partnership filed its return on time but inadvertently omitted the section 754 election that would…
PLR 200903068: Partnership received 60 days to file an omitted section 754 election
Interests in a limited liability company treated as a partnership were transferred during a tax year. The partnership timely filed its return and reported basis adjustments as though a section 754…
PLR 200903067: Convertible notes did not end S status after inadvertent-termination relief
An S corporation issued notes that could convert into its stock. Because convertible debt can be treated as a second class of stock, the notes may have terminated the company’s S election before…
PLR 200903066: Late QSST elections preserved the corporation’s S status
An S corporation shareholder transferred shares to two trusts that represented they qualified as qualified subchapter S trusts. The trusts’ beneficiaries failed to make timely QSST elections, making…
PLR 200903065: Corporation received 60 days to make its intended late S election
A corporation intended to elect S corporation treatment from its incorporation date but did not timely file Form 2553. It asked the IRS to treat the election as timely under section 1362(b)(5). The…
PLR 200903064: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes. Because of an inadvertent error, it did not timely file Form 8832 for the intended…
PLR 200903063: Foreign entity received 60 days to file a late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes. Because of an inadvertent error, it did not timely file Form 8832 for the intended…
PLR 200903062: Late QSub election and inadvertent-termination relief preserved S treatment
An S corporation acquired a subsidiary and made a section 338(h)(10) election, intending the subsidiary to be disregarded afterward. A tax adviser incorrectly said no qualified subchapter S…
PLR 200903061: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903060: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903059: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903058: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903057: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903056: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another corporation in the same foreign country whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S.…
PLR 200903055: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903054: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903053: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903052: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903051: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903050: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903049: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903048: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903047: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903046: Acquired foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903045: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903044: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903043: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903042: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903041: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
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.