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 200844005: Foreign subsidiary received extra time for disregarded status election
A taxpayer acquired a foreign company through tiered disregarded entities, and the acquired company owned several foreign limited-company subsidiaries. The taxpayer intended those subsidiaries to…
PLR 200844004: Foreign subsidiary received extra time for disregarded status election
A taxpayer acquired a foreign company through tiered disregarded entities, and the acquired company owned several foreign limited-company subsidiaries. The taxpayer intended those subsidiaries to…
PLR 200844003: Foreign subsidiary received extra time for disregarded status election
A taxpayer acquired a foreign company through tiered disregarded entities, and the acquired company owned several foreign limited-company subsidiaries. The taxpayer intended those subsidiaries to…
PLR 200844002: Foreign pension arrangement was classified as a trust
A foreign pension arrangement provided retirement, disability, and survivor benefits to covered employees and their surviving relatives. It received employer and employee contributions, invested…
PLR 200844001: Foreign entity received extra time for disregarded status election
A foreign eligible entity intended to elect disregarded-entity status from its formation date but did not file the entity-classification election on time. The classification regulations permit…
PLR 200843044: Teacher development award procedures received advance approval
A private foundation proposed awards that would fund learning experiences for public high school teachers in the first five years of their careers. Principals would nominate teachers, an independent…
Other 200843043: Business referral group was denied § 501(c)(6) exemption
A limited liability company sought § 501(c)(6) exemption as a business league, but its main activity was exchanging business leads among members from different occupations. Membership allowed only…
PLR 200843042: IRA trust used oldest beneficiary’s life expectancy and transferred tax-free
An IRA owner died before beginning required distributions and had designated a testamentary trust for his son as beneficiary. The trust paid income and permitted support distributions to the son,…
PLR 200843041: Common-control foundation merger avoided most Chapter 42 taxes
Two § 501(c)(3) private foundations with identical boards and officers proposed merging the nonoperating foundation into the operating foundation, which would survive and later become nonoperating.…
PLR 200843040: Common-control foundation merger avoided most Chapter 42 taxes
Two § 501(c)(3) private foundations with identical boards and officers proposed merging the nonoperating foundation into the operating foundation, which would survive and later become nonoperating.…
PLR 200843039: Dissolving charities could transfer restricted and unrestricted funds
Two public charities planned to end their operations and transfer all assets to a § 501(c)(3) supporting organization as part of a reorganization. One transfer included funds restricted to an…
PLR 200843038: Dissolving charities could transfer restricted and unrestricted funds
Two public charities planned to end their operations and transfer all assets to a § 501(c)(3) supporting organization as part of a reorganization. One transfer included funds restricted to an…
PLR 200843037: Dissolving charities could transfer restricted and unrestricted funds
Two public charities planned to end their operations and transfer all assets to a § 501(c)(3) supporting organization as part of a reorganization. One transfer included funds restricted to an…
PLR 200843036: Disability-services property rental was substantially related use
A charity financed a building that would house a disability-focused fitness center, an existing program, and space leased to another charity employing people with severe disabilities. The tenant’s…
Other 200843035: Shopping center merchant group was denied business-league exemption
A merchant association sought § 501(c)(6) exemption, but its membership was concentrated in one privately owned shopping center and its main activity was promoting that center and named merchants.…
Other 200843034: Real estate board was denied exemption for member-only MLS
A real estate board sought § 501(c)(6) exemption while operating a multiple listing service that produced more revenue than its membership dues. The public could search homes, but paying members…
Other 200843033: Political campaign activity defeated social-welfare exemption
An organization affiliated with a national faith-based advocacy group sought § 501(c)(4) social-welfare exemption. Its activities included precinct organizing, leadership training, candidate-focused…
Other 200843032: Pastor-controlled church was denied exemption for private benefit
A small religious organization sought § 501(c)(3) recognition and church classification while its pastor and the pastor’s spouse were its only voting members and trustees. The bylaws gave the pastor…
TAM 200843031: Inventory workpaper request put royalty method under consideration
A food manufacturer under examination filed Form 3115 during the 90-day window to change how it capitalized royalty costs under § 263A. Before the filing, the examination team had issued an…
PLR 200843030: Ineligible trust and partnership owners did not end S status
An S corporation’s election terminated when an ineligible trust acquired its stock after a shareholder’s death. The stock was later treated as owned through successive family beneficiaries and then…
PLR 200843029: Contingent divorce payments qualified as deductible alimony
A divorce agreement required monthly payments to an ex-spouse for a stated period, with possible increases tied to the payor’s salary and bonuses. The agreement did not expressly say whether…
PLR 200843028: LLC received 60 days to make late S election
A limited liability company timely elected association status on Form 8832 and intended S corporation treatment from the same date. It did not timely file Form 2553. Section 1362(b)(5) permits a…
PLR 200843027: Late ESBT election did not terminate S corporation status
A grantor trust held S corporation stock and remained an eligible shareholder for two years after its owner died. It then became ineligible because the trustee did not timely elect electing small…
PLR 200843026: Vehicle service contracts were insurance and indemnity was reinsurance
A subsidiary issued vehicle service contracts covering economic loss from mechanical breakdowns and related rental, towing, and road-service costs. It did not perform repairs, and an unrelated…
PLR 200843025: Family business split-off received specified Type D reorganization rulings
Two family shareholder groups disagreed over whether to expand a corporation’s two long-running businesses. The corporation proposed transferring one business and its related liabilities to a new…
PLR 200843024: Subsidiary and REIT liquidations and reincorporations received tax-free treatment
A public corporate group proposed a multi-step restructuring involving a subsidiary, three subsidiary REITs, disregarded limited liability companies, and a newly formed REIT. One subsidiary would…
PLR 200843023: Cooperative commodity checks were cash per-unit retain allocations
A nonexempt cooperative marketed a commodity for members and paid them through semimonthly checks plus year-end patronage dividends. The checks reflected the quantity delivered, arose under…
PLR 200843022: Foreign entity received extra time for partnership election
A foreign eligible entity with more than one owner intended partnership classification from a specified effective date but did not timely file Form 8832. The entity-classification regulations allow…
PLR 200843021: Family shareholders could split an S corporation business tax-free
Two related shareholder groups disagreed over how to operate an S corporation’s active business. The corporation proposed transferring part of the business and related liabilities to a new…
PLR 200843020: Converted partnership received extra time for corporate election
A domestic corporation converted into a limited partnership under state law but intended to remain classified as an association taxable as a corporation for federal tax purposes. It inadvertently…
PLR 200843019: Converted partnership received extra time for corporate election
A domestic corporation converted into a limited partnership under state law but intended to remain classified as an association taxable as a corporation for federal tax purposes. It inadvertently…
PLR 200843018: Converted partnership received extra time for corporate election
A domestic corporation converted into a limited partnership under state law but intended to remain classified as an association taxable as a corporation for federal tax purposes. It inadvertently…
PLR 200843017: Software-omitted tax-year change form was treated as timely
A C corporation intended to include Form 1128 with its timely electronic return to change its annual accounting period under the automatic-consent procedure. Its accounting firm timely filed the…
PLR 200843016: Cooperative could add member checks back for § 199 calculation
An agricultural cooperative and its cooperative subsidiary processed and marketed members’ commodity deliveries through an annual closed pool. Members received periodic checks as advances on net…
PLR 200843015: Cooperative could add member checks back for § 199 calculation
An agricultural cooperative processed and marketed members’ commodity deliveries through an annual closed pool. Members received periodic checks as advances on net proceeds and a final patronage…
PLR 200843014: Foreign company received extra time for partnership election
A foreign limited-liability company with two owners intended partnership classification from its formation date but did not timely file Form 8832. Because all members had limited liability, the…
PLR 200843013: C-code licensing income qualified as active software royalties
A software developer licensed C-code through two models: semiconductor manufacturers embedded it in chips used by licensed product makers, while other licensees compiled it directly into software or…
PLR 200843012: Insolvent insurance subsidiary remained in its parent’s consolidated group
A parent corporation wholly owned an insurance subsidiary that once qualified as a life insurance company and therefore was excluded from the parent’s consolidated group. The subsidiary later ceased…
PLR 200843011: Business separation qualified as a tax-free reorganization and distribution
A corporate group proposed separating two active businesses. It would first merge a subsidiary into a disregarded entity, contribute interests holding one business to a newly formed controlled…
PLR 200843010: Foreign entity received an extension to elect partnership status
A foreign eligible entity intended to be treated as a partnership from its formation date but inadvertently failed to file Form 8832 on time. A foreign entity whose owners all have limited liability…
PLR 200843009: Late S corporation election was treated as timely
A corporation intended to elect S corporation status effective from its incorporation date but did not file Form 2553 on time. Section 1362 generally delays an election filed after the first two and…
PLR 200843008: Missed trust elections did not end S corporation status
An S corporation transferred shares to seven trusts that represented they qualified as electing small business trusts, but their trustees failed to make the required ESBT elections. The trusts…
PLR 200843007: Trust ownership caused an inadvertent S corporation termination
An S corporation’s stock was held by a grantor trust. After the deemed owner died, the trust remained an eligible shareholder for two years but then became ineligible and terminated the S election.…
PLR 200843006: Post-death trust ownership inadvertently terminated S status
An S corporation’s stock was held by a grantor trust that ceased to be a grantor trust when its deemed owner died. The trust remained an eligible S corporation shareholder for two years, but then…
PLR 200843005: Foreign entity received more time to elect disregarded status
A wholly owned foreign entity changed its legal form and intended to be treated as disregarded from the conversion date. It did not file Form 8832 on time. The entity represented that it had acted…
PLR 200843004: Pro rata business spin-off qualified for nonrecognition
A corporation operating two active businesses proposed moving one business to a new controlled corporation and distributing all of the controlled corporation’s stock pro rata to its shareholders.…
PLR 200843003: Corporation received more time to make its DISC election
A domestic corporation was formed to operate as an interest charge domestic international sales corporation, but neither of its outside advisers filed the required Form 4876-A within 90 days of its…
PLR 200843002: Missed ESBT elections caused an inadvertent S termination
Two trusts received stock in an S corporation and represented that they qualified as electing small business trusts, but their trustee failed to make ESBT elections. That failure made the trusts…
PLR 200843001: Rescinded stock sale did not change disregarded entity status
A foreign entity intended to be classified as disregarded from its formation date under a separately granted late-election ruling. Its sole shareholder later sold part of the entity’s stock to…
Other 200842058: Mutual insurer lost its tax exemption
A mutual property insurer had been recognized as exempt under § 501(c)(15). The IRS examination found that the insurer’s gross receipts were within the $600,000 ceiling but premiums were not more…
Other 200842057: Health-care organization lost exemption after ceding control to a for-profit lessee
A nonprofit health-care organization leased its facility and operations to a for-profit corporation. The lease gave the for-profit operator effective control while the nonprofit received fixed rent,…
Other 200842056: Trust lost exemption after refusing to provide records
A trust treated like a § 501(c)(3) organization under § 4947(a)(1) repeatedly refused to provide records during an IRS examination. Its representatives did not return calls, declined certified…
Other 200842055: Local adult club did not qualify as an amateur sports charity
An adult membership club had previously been reclassified from § 501(c)(4) to § 501(c)(3) after amending its articles to state charitable, educational, and amateur-sports purposes. Its actual…
Other 200842054: Private foundation lost exemption for unsubstantiated operations
A trust recognized as a private foundation said it existed to fund charitable and educational organizations. Its trustee described a business investment financed by a company loan, and trust checks…
Other 200842053: Seller-funded down payment program served private interests
A nonprofit provided home buyers with down payment grants funded almost entirely by service fees from the sellers in the same transactions. The fee generally equaled the grant plus an administrative…
Other 200842052: Mutual insurer exceeded the gross-receipts ceiling for exemption
A mutual property and casualty insurer had been exempt under § 501(c)(15). After correcting how the company classified policy fees, service charges, reinsurance payments, commissions, and expenses,…
Other 200842051: Paid gaming operation did not further an exempt purpose
An organization recognized under § 501(c)(3) operated charitable gaming but made only limited charitable contributions. Its gaming report treated transfers from the gaming bank account to its own…
Other 200842050: Commercial real-estate activity displaced the charity’s exempt purpose
A charity’s stated purposes were helping economically and socially deprived children, providing job training, and offering substance-abuse services. During the examined years, however, it primarily…
Other 200842049: Inactive reinsurance program no longer qualified as an insurer
A state-created nonprofit reinsurance program had previously received exemption under § 501(c)(15), but no carriers participated during the examined years. It collected no premiums, issued or…
PLR 200842048: Divorce-plan distribution received a late-rollover waiver
A former spouse received a retirement-plan interest under a qualified domestic relations order that required a lump-sum distribution. The plan’s notice suggested annual withdrawals and omitted its…
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.