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 200724006: Community time exchange is not a barter exchange under section 6045
A public charity coordinated a neighborhood exchange of services and goods, recording hours as credits without charging members fees. An hour of any service earned the same credit, and credits gave…
PLR 200724005: Late S corporation election treated as timely if Form 2553 is filed
A corporation intended S corporation status from its incorporation date but did not file Form 2553 on time. It represented that its tax returns had been filed consistently with S corporation status.…
PLR 200724004: Fund's preferred-to-common stock exchange is not a new acquisition
A closed-end interval fund held preferred stock in a private company that became common stock when the company went public. The fund could not sell the new shares for about six months under a…
PLR 200724003: Two-shareholder company may file late S election
Two shareholders intended S corporation status for their company from its incorporation date, but Form 2553 was not filed on time. The IRS found reasonable cause for the late election. It ruled that…
PLR 200724002: Professional LLC gets late corporate and S election relief
A professional limited liability company intended corporate and S corporation tax treatment from a specified date, but neither Form 8832 nor Form 2553 was filed on time. Its accountant later filed a…
PLR 200724001: Couple gets more time to allocate generation-skipping tax exemption
A couple made transfers to a descendants' trust over five years and intended to allocate generation-skipping transfer tax exemption so the trust would have a zero inclusion ratio. Their tax preparer…
PLR 200723034: Surviving spouse receives waiver of IRA rollover deadline
A surviving spouse took a distribution from the deceased spouse's IRA but did not roll it into another IRA within 60 days. The spouse said a longtime financial adviser had recommended surrendering…
PLR 200723033: Medical impairment warrants waiver of IRA rollover deadline
An IRA owner withdrew amounts from two IRAs and placed them in a non-IRA account. The owner's wife, acting under a power of attorney, said a neurological condition had impaired his judgment and…
PLR 200723032: Regulatory consolidation preserves two business leagues' exemption
Two exempt organizations that regulate an industry proposed taking over member regulatory functions from an organization linked to a for-profit company. The transaction required governance changes…
PLR 200723031: Endowment contracts with charitable remainder trusts do not create UBTI for school
An exempt educational institution proposed giving charitable remainder trusts contractual rights tied to its endowment's value and payout rate. The institution was trustee and sole charitable…
PLR 200723030: Disease charity may operate specialty pharmacy through disregarded LLC
A disease research and patient support charity proposed merging its taxable pharmacy subsidiary into a wholly owned LLC. The LLC would continue supplying disease-related products and services to…
PLR 200723029: Member regulator consolidation and payment preserve exemption
Two section 501(c)(6) organizations proposed combining their industry member regulation work with functions transferred from an organization owned by a for-profit company. The transaction included a…
IRS determination 200723027: Captive insurer loses its tax exemption
A company formed a captive insurer to cover risks of its parent and affiliates and obtained recognition of exemption under § 501(c)(15). It also received an interest in a holding company that owned…
PLR 200723026: Pension funding waivers granted with conditions
A foundry company sought waivers of its pension plan's minimum funding standard for two plan years after falling into bankruptcy and selling its operating assets. A sister company in the same…
PLR 200723025: Unequal shareholder distributions did not end S corporation election
An S corporation made extra distributions to help shareholders pay taxes, but those payments were not proportional to their ownership interests. After learning of the problem, it adopted a…
PLR 200723024: Purchaser gets more time to elect asset treatment for stock purchase
A purchaser acquired all the stock of a foreign corporation and missed the deadline to file a § 338(g) election, which can treat a qualifying stock purchase as an asset acquisition for tax purposes.…
PLR 200723023: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723022: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723021: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723020: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723019: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723018: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723017: More time to identify buildings in a housing credit project
A taxpayer failed to properly identify specific buildings as part of one multiple building project for the low income housing credit. Based on the taxpayer's representations, the IRS granted more…
PLR 200723016: Late S corporation election accepted if filed within 60 days
A corporation's sole shareholder intended the business to be an S corporation, but its Form 2553 election was filed late. The IRS found reasonable cause for the delay and granted relief under §…
PLR 200723015: REIT adviser reimbursements count toward qualifying income tests
A real estate investment trust arranged for its investment adviser to reimburse some operating expenses to keep costs reasonable for shareholders. The REIT asked whether those payments count as…
PLR 200723014: Splitting a marital trust avoids gain, but ending one part triggers a gift
A trustee proposed to divide a marital trust into two trusts, then end one and distribute its assets to the surviving spouse and a child according to the value of their interests. The IRS ruled that…
PLR 200723013: Foreign entity gets more time to elect disregarded status
A foreign entity with one owner intended to elect treatment as an entity disregarded from its owner for federal tax purposes, effective when it was incorporated. It missed the deadline to file Form…
PLR 200723012: S corporation status restored after wrong trust election
An S corporation transferred shares to a trust that could have elected to be an electing small business trust (ESBT), but an invalid qualified subchapter S trust election was filed instead. The IRS…
PLR 200723011: More time to report surviving spouse's citizenship for a QDOT
A surviving spouse became a United States citizen after a qualified domestic trust (QDOT) was set up following the decedent's death. The trustee missed the deadline to file a final Form 706-QDT…
PLR 200723010: More time to file dual consolidated loss elections
A taxpayer's accountants omitted election agreements and some annual certifications relating to dual consolidated losses from several foreign branches and other separate units. The taxpayer…
PLR 200723009: Partnership gets more time to elect a basis adjustment
A partnership failed to file a § 754 election for the year in which a partner died and the tax ownership of a trust holding a partnership interest changed. That election allows adjustments to the…
PLR 200723008: Corporation gets more time to elect DISC treatment
A corporation intended to elect treatment as an interest charge domestic international sales corporation (DISC), but its accountant and the corporation each thought the other would file Form 4876-A.…
PLR 200723007: Revised nuclear decommissioning fund payment schedule approved
A public utility requested a revised schedule of permitted payments to its qualified nuclear decommissioning fund after a regulator extended the plant's estimated life. The requested revision…
PLR 200723006: Moving old trust assets preserves GST exemption, with an estate tax exception
A trustee proposed to move the assets of two irrevocable trusts into a new trust for a beneficiary and her children. The IRS ruled that the transfer itself would not make anyone the owner of the new…
PLR 200723005: Late S corporation election may be filed within 60 days
A corporation's shareholders intended to elect S corporation status from the date it was incorporated, but the election was not filed on time. The IRS found reasonable cause for the missed deadline…
PLR 200723004: S corporation status restored after wrong trust election
An S corporation transferred shares to a trust that could have elected to be an electing small business trust (ESBT), but an invalid qualified subchapter S trust election was filed instead. The IRS…
PLR 200723003: S corporation status restored after wrong trust election
An S corporation transferred shares to a trust that could have elected to be an electing small business trust (ESBT), but an invalid qualified subchapter S trust election was filed instead. The IRS…
PLR 200723002: Late dual consolidated loss elections allowed for foreign branches
A taxpayer failed to file election agreements for dual consolidated losses from several foreign branches and asked for more time to file those agreements and annual certifications. The taxpayer had…
PLR 200723001: Business separation receives nonrecognition rulings for specified steps
A corporation planned to put one business into a new corporation and distribute the new company's stock to its existing shareholders. The separation was intended to let the new company pursue…
PLR 200722031: Spouse's IRA rollover clock starts when she receives the corrected payment
A retirement plan paid a deceased participant's account to his estate using an outdated beneficiary designation, although his surviving spouse was the named beneficiary. The estate returned the…
PLR 200722030: IRA rollover deadline waived after a bank moved funds to the wrong account
An 83-year-old IRA owner asked his financial institution to move money between investments inside his IRA. A representative misunderstood and moved it into a non-IRA account without telling him. The…
PLR 200722029: Estate option sale and note to foundation avoid self-dealing
A private foundation expected to receive property from the estate or revocable trust of the survivor of a married couple. An existing option let a company buy specified stock and related assets from…
PLR 200722028: Breast cancer awareness merchandise sales further charity's mission
A breast cancer charity and its affiliates sold merchandise tied to their public education work. The items displayed an awareness symbol or its color, and buyers received information about breast…
CCA 200722027: Service receivables cannot use installment reporting on partnership sale
Chief Counsel analyzed a cash-method partner's sale of a partnership interest for a promissory note. Part of the sale proceeds reflected the partnership's unpaid rights to compensation for services.…
CCA 200722026: Donations for families of fallen firefighters qualify as charitable gifts
Chief Counsel considered donations to a charity intended for the families of five firefighters killed in the Esperanza Incident fire. Gifts earmarked for named individuals ordinarily are not…
PLR 200722025: Settlement fund faces limited reporting and backup withholding duties
A qualified settlement fund planned to compensate mutual fund investors harmed by improperly calculated advisory fees. The IRS ruled that most payments did not require information reporting under §…
PLR 200722024: Partnership gets more time to elect corporate tax classification
A limited partnership intended to elect treatment as a corporation when it was formed, but its Form 8832 was not filed on time. The IRS found that the entity met the standards for an extension of…
PLR 200722023: LLC gets more time to elect corporate tax treatment
A limited liability company intended to file Form 8832 to be taxed as a corporation from a specified date, but it missed the filing deadline. The IRS found that the company satisfied the standards…
PLR 200722022: Void share transfer did not end S corporation election
A shareholder tried to transfer S corporation shares to a trust, but a court ruled that the transfer was void under state law. The IRS concluded that the trust never became a shareholder, so the…
PLR 200722021: Entity gets more time to elect corporate tax classification
An entity intended to elect treatment as a corporation when it was formed, but its Form 8832 was not filed on time. The IRS found that the entity met the standards for an extension of time under the…
PLR 200722020: Late S corporation election accepted with Form 2553 filing
A corporation's shareholder intended S corporation treatment from incorporation, but the election was not filed on time. The IRS found reasonable cause for the missed filing and ruled that the…
PLR 200722019: Late S corporation election accepted with Form 2553 filing
A corporation's shareholder intended S corporation treatment from incorporation, but the election was not filed on time. The IRS found reasonable cause for the missed filing and ruled that the…
PLR 200722018: Reformed trust qualifies as an S corporation shareholder trust
A trust that owned S corporation stock had elected treatment as an electing small business trust. Its trustee obtained a court order reforming the trust so it could instead meet the requirements for…
PLR 200722017: Sole shareholder's late S corporation election may be filed
A corporation's sole shareholder intended S corporation treatment from incorporation, but Form 2553 was not filed on time. The IRS found reasonable cause for the delay under § 1362(b)(5). It ruled…
PLR 200722016: Entity gets more time to elect corporate tax classification
Members of an entity intended to elect treatment as a corporation when it was formed, but its Form 8832 was not filed on time. The IRS found that the entity met the standards for an extension of…
PLR 200722015: Foreign entity gets more time to elect disregarded treatment
A foreign entity intended to elect treatment as disregarded from its owner as part of a corporate reorganization. A communication failure in its parent's tax department caused it to miss the Form…
PLR 200722014: Reformed trust qualifies as an S corporation shareholder trust
A trust that owned S corporation stock had elected treatment as an electing small business trust. Its trustee obtained a court order reforming the trust so it could instead meet the requirements for…
TAM 200722013: Utility deregulation did not qualify for involuntary conversion deferral
A regulated electric utility sought to defer gain under § 1033 after its state restructured the electricity market and the utility sold six power plants. The utility argued that deregulation…
PLR 200722012: Foreign entity gets more time to elect partnership treatment
A foreign entity intended to elect partnership classification for federal tax purposes but did not file Form 8832 on time. It requested an extension under the election relief rules in Treasury…
PLR 200722011: Corrective distributions preserve S corporation treatment
An S corporation made distributions that were not proportional to shareholders' ownership interests. It tried to correct them, but clerical errors left some payments slightly inaccurate. The IRS…
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.