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 200735023: Estate gets time to split marital trust and make reverse QTIP election
An estate's return indicated that its marital trust would be split into trusts with and without generation-skipping transfer tax exemption, but the split was not completed and the preparer omitted a…
PLR 200735022: Bank holding company keeps S status after director share agreements
A bank holding company sold one share to each bank director to satisfy a banking law requirement. The agreements gave the majority shareholder the dividends and the right to buy back each share at a…
PLR 200735021: Donations to state tourism foundation can be deductible
A foundation created by state law raised and managed contributions for a statewide tourism program. State officials controlled its board and administration, government bodies supplied most of its…
TAM 200735020: Broad LIFO inventory groups distort reported inflation
Members of a consolidated group used last-in, first-out inventory accounting, with some using dollar-value LIFO and others using specific-goods LIFO. They grouped products with different uses and…
PLR 200735019: Redemption of university endowment units produces capital gain or loss
A charitable remainder unitrust planned to give assets to a university in exchange for units tied to the value of the university's endowment. The units would provide quarterly payouts, but their…
PLR 200735018: Late GST exemption allocations allowed for three trusts
A taxpayer made transfers to three trusts, each benefiting one daughter and her descendants. She intended to use her generation-skipping transfer tax exemption for the transfers, but the…
PLR 200735017: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735016: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735015: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735014: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735013: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735012: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735011: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735010: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735009: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735008: Nuclear decommissioning funds transfer with carryover basis
Four utilities transferred interests in a nuclear plant and their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that transferring the fund…
PLR 200735007: Late GST exemption allocation allowed for a gift-split trust transfer
A husband transferred property to a trust for his descendants, and the spouses elected to split the gift for gift tax purposes. Their tax professional failed to allocate their generation-skipping…
PLR 200735006: Husband allowed late GST exemption allocation for a trust transfer
A husband transferred property to a trust for his descendants, and the spouses elected to split the gift for gift tax purposes. Their tax professional failed to allocate their generation-skipping…
PLR 200735005: Foreign corporation gets more time to file nonrecognition notice
A foreign corporation distributed stock of a U.S. real property holding corporation to its foreign parent in a complete liquidation under section 332. Neither company timely filed the notice…
PLR 200735004: Foreign corporation gets more time to file nonrecognition notice
A foreign corporation distributed stock of a U.S. real property holding corporation to its foreign parent in a complete liquidation under section 332. Neither company timely filed the notice…
PLR 200735003: Three S corporations combine under a new S corporation parent
The shareholders of three S corporations contributed their shares to a new corporation, which planned to elect S corporation status and treat each former corporation as a qualified subchapter S…
PLR 200735002: Foreign purchaser gets 45 days to file a section 338 election
A foreign purchaser acquired all the stock of a foreign corporation through a disregarded entity but missed the deadline for a section 338(g) election, which can treat a stock purchase as an asset…
PLR 200735001: Four S corporation subsidiaries may be spun off to shareholders
An S corporation planned to distribute the stock of four wholly owned subsidiaries to its shareholders so the businesses could operate in separate corporations. The distributions would end the…
PLR 200734026: New problem solving programs preserve educational charity status
A public charity offered creativity and problem solving programs for young people. It proposed similar programs for adults, very young children, and college students, and asked whether those…
PLR 200734025: Pension trust may admit locals from merged union
A tax-exempt pension trust for union members wanted to amend its governing document after a union merger. The amendment would let additional local unions participate while keeping the trust's…
PLR 200734024: Foundation's art loans and planned museum further education
A private foundation planned to shift from primarily making arts grants to lending its artwork for public exhibition and eventually operating a museum and research library. The IRS ruled that these…
PLR 200734023: Partnership liquidations and ruling costs avoid foundation excise taxes
A private foundation held interests in three real estate partnerships alongside other partners, some connected to foundation directors. The partnerships proposed to liquidate and distribute their…
PLR 200734022: Pension plan transfer and funding allocation methods approved
A former subsidiary facing bankruptcy planned to move some pension benefits and assets from its underfunded plan back to its former parent's plan. The transfer would spin off part of the…
CCA 200734021: Severely damaged home treated as destroyed under section 121
A natural disaster damaged a taxpayer's principal residence so severely that rebuilding would require extensive demolition and cost more than the home's value before the disaster. Chief Counsel…
CCA 200734020: Criminal tax restitution does not itself settle civil tax liability
A taxpayer convicted of tax evasion was ordered by a federal court to pay restitution to the IRS in monthly installments. Chief Counsel advised that the order was a criminal restitution obligation,…
CCA 200734019: Estate's loss carryover cannot offset an ESBT's S portion
A testamentary trust inherited an unused net operating loss carryover when an estate ended. The trust held S corporation stock and later elected to be an electing small business trust (ESBT). Chief…
PLR 200734018: Foreign pension arrangement classified as a trust
A pension arrangement organized under a foreign country's laws provided retirement and related benefits to workers covered by a collective labor agreement. Its board managed and invested…
PLR 200734017: Late S corporation election accepted for incorporation date
A newly incorporated company intended to elect S corporation status from its incorporation date but did not file the election on time. The IRS found reasonable cause and said it would treat the…
PLR 200734016: Foreign entity gets 60 days for late partnership election
A foreign entity intended to elect partnership treatment for U.S. federal tax purposes from its formation date but failed to file Form 8832 on time. The entity represented that it was eligible to…
PLR 200734015: Replacement ruling grants late QSub election and termination relief
A parent S corporation missed the deadline to elect qualified subchapter S subsidiary (QSub) status for a subsidiary. A later restructuring temporarily left the parent with less than full ownership…
PLR 200734014: S corporation status restored after shares reached ineligible owner
An S corporation transferred shares to an ineligible shareholder, which terminated its S election. Income from those shares had been reported by two eligible shareholders, and the company later…
PLR 200734013: Two-step spin-off and merger receive specified tax treatment
A public company's subsidiary planned to transfer assets to another subsidiary, distribute that subsidiary's stock up to its parent, and have the parent distribute the stock to shareholders. The…
PLR 200734012: S corporation status preserved after trust missed ESBT election
An estate transferred S corporation shares to a trust that failed to elect electing small business trust (ESBT) status on time. The IRS concluded that the missed trust election terminated the…
PLR 200734011: Two late trust elections do not end S corporation treatment
An S corporation's shares were transferred to two trusts that failed to elect electing small business trust (ESBT) status on time. The IRS concluded that the first transfer terminated the S election…
PLR 200734010: Trustee appointment changes preserve old trust's GST exemption
A trust created before 1942 gave each of three beneficiaries a lifetime right to request principal and a separate power to direct remaining property to descendants by will. A proposed trustee…
PLR 200734009: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734008: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734007: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734006: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734005: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734004: Nuclear decommissioning fund transfers and excess contributions approved
Two utilities transferred their interests in a nuclear plant and the assets of their qualified decommissioning funds to a related company that assumed decommissioning duties. The IRS ruled that…
PLR 200734003: Trust assets pass through an LLC to beneficiaries without gain
A trust planned to transfer all its assets and liabilities to a new limited liability company, then terminate and distribute company interests to its beneficiaries. The IRS treated the first…
PLR 200734002: Foreign insurer gets 60 days for domestic corporation election
A foreign insurance company wanted to elect treatment as a U.S. domestic corporation from the start of an earlier tax year. Its original tax advisers had not told it that a section 953(d) election…
PLR 200734001: Sole-owner company gets relief for late S election
A company's sole shareholder intended S corporation status from the date of incorporation, and both the company and owner reported income consistently with that intent. The company missed the Form…
IRS determination 200733034: Debt management organization loses tax exemption
The IRS revoked a credit counseling organization's section 501(c)(3) exemption. The examination report says its main activity was marketing debt management plans and that it provided little…
PLR 200733033: University endowment shares avoid unrelated business income
An exempt educational organization planned to issue contractual shares in its endowment to charitable remainder trusts for which it served as trustee. The trusts would receive payouts tied to the…
PLR 200733032: Trust's endowment contract payouts avoid unrelated business income
A charitable remainder trust asked whether its contractual share of a university endowment would produce unrelated business taxable income. The trust would receive payouts based on the endowment's…
IRS determination 200733031: Seller funded homebuyer aid costs charity its exemption
The IRS revoked a down payment assistance organization's section 501(c)(3) exemption effective on a redacted September 1 date. Home sellers paid the organization amounts matching the assistance…
PLR 200733030: Health education events and free facility use avoid unrelated business tax
A health policy research foundation asked whether events with sponsoring organizations and free use of its conference center and studio by other charities would count as unrelated business. The IRS…
PLR 200733029: ESOP loan repayment and stock transfers receive favorable rulings
A financial holding company planned to terminate its leveraged employee stock ownership plan after business losses. It would redeem unallocated company shares to repay the plan's loan, allocate…
IRS determination 200733028: Injury charity denied exemption over family benefit
A charity formed after a family member's spinal cord injury sought section 501(c)(3) exemption. It raised money for people with similar injuries, but spent substantial funds on that family member's…
IRS determination 200733027: Used boat seller denied charitable exemption
An organization proposed to collect donated used ski boats, repair them, and sell them to nonprofit youth camps. It expected to sell most boats rather than give them away and to use sales proceeds…
PLR 200733026: Health education events and free facility use avoid unrelated business tax
A health policy research foundation asked whether events with sponsoring organizations and free use of its conference center and studio by other charities would count as unrelated business. The IRS…
PLR 200733025: Corporate spin off and stock exchange receive tax rulings
A corporate group proposed to separate one business, distribute shares through its ownership chain, and combine the separated company with another business under a new holding company. The IRS…
TAM 200733024: Foreign trust beneficiaries face PFIC tax on liquidation gain
The IRS analyzed a foreign trust's gain from a liquidating distribution by a corporation it classified as a passive foreign investment company. It concluded that the trust's U.S. beneficiaries could…
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.