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 200720006: Family receives more time to allocate GST exemption to trust gifts
A husband and wife made gifts to a trust for their descendants and intended to allocate generation-skipping transfer (GST) tax exemption to the gifts. Their tax adviser mistakenly said some gift tax…
PLR 200720005: Eleven mortgage trusts receive late REMIC election relief
Eleven mortgage trusts intended to elect real estate mortgage investment conduit (REMIC) status on their first tax returns. The preparer sent the returns to the trustee with instructions to sign and…
PLR 200720004: Group annuity contract retains its tax classification
Two taxpayers asked whether a group annuity contract still qualified as an annuity after changes to its terms and an increase in certificate holders. They also asked whether a later IRS ruling about…
PLR 200720003: Corporation receives relief for late S election
A corporation intended to be taxed as an S corporation from its incorporation date but did not file its election on time. The IRS found reasonable cause for the late filing under IRC § 1362(b)(5).…
PLR 200720002: Corporation receives relief for late S election
A corporation intended to be taxed as an S corporation from its incorporation date but did not file its election on time. The IRS found reasonable cause for the late filing under IRC § 1362(b)(5).…
PLR 200720001: Corporation receives relief for late S election
A corporation intended to be taxed as an S corporation from its incorporation date but did not file its election on time. The IRS found reasonable cause for the late filing under IRC § 1362(b)(5).…
PLR 200719019: IRA owner gets rollover relief after brokerage transfer error
An IRA owner asked to move her retirement funds to a new brokerage, but the receiving firm deposited them into her ordinary brokerage account. Its representative had checked the wrong transfer…
PLR 200719018: Widow's late rollover of husband's annuity proceeds is accepted
A man withdrew funds from his section 403(b) annuity and intended to put them back, but hospitalization and his death prevented a rollover within 60 days. His widow, acting as his estate's personal…
PLR 200719017: IRA settlement proceeds may restore losses without contribution limits
A married couple settled an arbitration claim against their brokerage over alleged misconduct that caused losses in two IRAs and a separate taxable account. The settlement did not assign a share to…
PLR 200719016: IRS denies late IRA rollover waiver after stroke claim
A taxpayer sought a waiver of the 60-day deadline to roll distributions from two IRAs into another IRA. The taxpayer said a stroke about two years earlier had impaired financial decision-making. The…
PLR 200719015: IRS waives late retirement plan rollover after planner's error
A taxpayer received distributions from a qualified retirement plan and met a financial planner before the 60-day rollover deadline. The planner failed to say the deadline would expire the next day,…
PLR 200719014: Governmental plan may accept rollovers to buy pension benefits
A city asked whether former police employees could use money from its governmental section 457 deferred compensation plan to buy additional benefits in its defined benefit pension plan. The IRS…
PLR 200719013: Museum transfer preserves foundation status; one question declined
A private operating foundation proposed transferring three museums to a related public charity for no payment while continuing its other charitable work. The IRS ruled that this partial transfer…
PLR 200719012: Museum transfer preserves foundation status; one question declined
A private operating foundation proposed transferring three museums to a related public charity for no payment while continuing its other charitable work. The IRS ruled that this partial transfer…
TAM 200719011: U.K. windfall tax fails foreign tax credit net gain test
A U.S. corporation sought a foreign tax credit tied to the United Kingdom's 1997 windfall tax on privatized utilities. The IRS advised that the tax did not meet the net gain requirement for a…
CCA 200719010: Business no longer covered by railroad retirement tax
The Railroad Retirement Board advised the IRS that a business had ceased to be a covered employer under the railroad retirement and unemployment insurance laws. The IRS reviewed the board's opinion…
PLR 200719009: Late taxable REIT subsidiary election treated as timely
A real estate investment trust and its subsidiary tried to elect taxable REIT subsidiary status on Form 8875, but their adviser filed a form missing the trust officer's signature and showing the…
PLR 200719008: Trust gets 60 more days to elect investment gain treatment
A trust had investment interest expense and capital gain from selling investment property, but its tax return omitted the election to count that gain as investment income. The election can increase…
PLR 200719007: S corporation may merge into corporate-taxed LLC without ending its election
An S corporation planned to merge into a newly formed limited liability company whose owners and ownership percentages would match the corporation's shareholders. The LLC would elect corporate tax…
PLR 200719006: S corporation may merge into corporate-taxed LLC without ending its election
An S corporation planned to merge into a newly formed limited liability company whose owners and ownership percentages would match the corporation's shareholders. The LLC would elect corporate tax…
PLR 200719005: S corporation may merge into corporate-taxed LLC without ending its election
An S corporation planned to merge into a newly formed limited liability company whose owners and ownership percentages would match the corporation's shareholders. The LLC would elect corporate tax…
PLR 200719004: Company gets more time to elect corporate tax classification
A company with multiple members had filed corporate income tax returns but had not filed Form 8832 to elect corporate tax classification. It said a qualified tax professional had failed to recommend…
PLR 200719003: Estate gets time to divide marital trust and elect GST treatment
An estate made an estate tax election for a marital trust but its attorney did not divide the trust into parts with and without generation-skipping transfer (GST) tax exemption or make a reverse…
PLR 200719002: QDOT trustee gets more time to report spouse's citizenship
A decedent's will established a qualified domestic trust because the surviving spouse was not a U.S. citizen. The spouse later became a citizen and told the estate's lawyers, but they failed to file…
PLR 200719001: Late S corporation election granted for requested effective date
A corporation's shareholders wanted S corporation treatment beginning on a redacted date, but the corporation did not file its election on time. The IRS found reasonable cause for the late filing…
PLR 200718038: Retiree medical accounts may receive funds after key employees retire
A defined benefit plan maintained pooled retiree medical funds for employees who were not key employees and separate medical accounts for key employees. The employer wanted to add funds to the…
PLR 200718037: Medical evidence supports late IRA rollover waiver
A taxpayer withdrew money from an IRA while receiving treatment for a neurological impairment that affected judgment and memory. The taxpayer deposited the proceeds in a regular account and missed…
PLR 200718036: Employer gets time to file separate lines of business notices
An employer operated several distinct businesses and applied the retirement plan rules separately to their workforces. It relied on a benefits consulting firm that sent the IRS information about…
Determination 200718035: Seller-funded down payment program denied charity exemption
An organization sought section 501(c)(3) exemption for a program that helped homebuyers make down payments. Its related organization received payments from participating home sellers after their…
Determination 200718034: Seller-funded homebuyer assistance group denied charity exemption
An organization applied for section 501(c)(3) exemption while raising funds for a related group’s down payment assistance program. Participating home sellers paid the applicant after closing, and a…
PLR 200718033: Foundation may transfer inherited property to botanical garden foundation
A private foundation expected to receive property and a vacant lot from a trust and planned to give both to another private foundation that operated botanical gardens. The recipient would use the…
PLR 200718032: Foundation property gift to botanical garden qualifies as distribution
A private foundation expected to inherit property and a vacant lot and planned to transfer them without payment to another private foundation that operated botanical gardens. The recipient would use…
PLR 200718031: Couple receives time to opt out of automatic GST allocation
A grantor funded a trust holding life insurance policies for a spouse and children. The couple relied on an accountant for tax returns, but gift tax returns were missed for several years, including…
CCA 200718030: Foreclosed property accounting change barred during audit
A financial services taxpayer used a lower of cost or market method to deduct declines in the value of foreclosed real estate before selling it. It asked to switch to deducting losses only when it…
CCA 200718029: Audit plan blocks foreclosed property expense method change
A financial services taxpayer deducted costs of preparing foreclosed real estate for sale when it incurred them. It sought to change its method so it would capitalize the costs and deduct them when…
PLR 200718028: Sale through intermediary identifies relinquished property on time
A taxpayer arranged a reverse like-kind real estate exchange in which an exchange accommodation titleholder acquired replacement property first. The taxpayer sold its relinquished property through a…
PLR 200718027: County hospital system may issue bonds for county
A county created a public corporation to operate its teaching hospital and provide health care, education, and research services. The county was the corporation’s sole member, appointed or could…
PLR 200718026: Late tax year change application treated as timely filed
A taxpayer filed Form 1128 after the deadline for requesting a change from a June 30 tax year to a December 31 tax year. It sought relief soon after the deadline. The IRS found that the taxpayer had…
PLR 200718025: Late S corporation election receives relief
A corporation’s sole shareholder intended to elect S corporation status from the date the company was incorporated, but Form 2553 was not filed on time. The IRS found reasonable cause for the missed…
PLR 200718024: Business separation qualifies as a Type D reorganization
A public company planned to separate one business into a controlled company, then distribute the controlled company’s shares through a spin-off or a split-off with a possible cleanup distribution.…
PLR 200718023: Missed S corporation election deadline excused
A corporation intended to elect S corporation treatment from its incorporation date, but failed to file Form 2553 on time. The IRS found reasonable cause for the late election. It ruled that the…
PLR 200718022: Corporation granted relief for late S election
A corporation’s shareholders intended S corporation status from a specified date, but its Form 2553 was not filed on time. The IRS found reasonable cause for the missed deadline and granted late…
PLR 200718021: Federal prisoner contract avoids private business use of jail bonds
A county planned to finance a new jail with bonds and allow a federal agency to place prisoners there when beds were available. The federal contract would run for less than 100 days at a time, could…
PLR 200718020: IRA share transfers treated as inadvertent S termination
An S corporation lost its S election when a shareholder transferred stock to two IRAs, which could not be eligible S corporation shareholders. After learning of the problem, the IRAs transferred the…
PLR 200718019: Family business split-off receives favorable tax rulings
Three related shareholders equally owned a parent corporation whose subsidiaries ran two separate businesses. To separate their management and ownership, the parent planned to exchange all of one…
PLR 200718018: Long-serving school staff retain Medicare tax exception after district merger
A referendum combined an elementary district with part of a high school district to create a unified school district. Some employees had worked for the original districts since before April 1, 1986,…
PLR 200718017: Foreign group receives time for real property interest notices
A foreign corporate group reorganized ownership of two domestic corporations but missed required statements and notices about whether their shares were U.S. real property interests. An officer and…
PLR 200718016: Late S corporation election receives conditional relief
A corporation intended to elect S corporation status from its incorporation date, but did not file its election on time. The IRS found reasonable cause for the late filing and ruled that the…
PLR 200718015: S election relief granted where filing was missing from IRS records
A corporation’s sole shareholder intended S corporation status from the incorporation date, but the IRS service center had no record of a timely Form 2553. The IRS found reasonable cause for the…
PLR 200718014: S corporation merger into LLC qualifies as Type F reorganization
An S corporation planned to merge into a newly formed LLC that would elect corporate tax classification. The same owners would hold identical percentages afterward, and the LLC agreement would give…
PLR 200718013: Foreign insurer gets time to elect domestic tax treatment
A foreign insurance company agreed in a reinsurance contract to elect treatment as a domestic corporation for U.S. tax purposes. The election was missed because administrative responsibilities had…
PLR 200718012: Foreign entity gets time for disregarded entity election
A foreign entity intended to elect treatment as disregarded from its owner from the date it was formed, but did not file Form 8832 on time. The IRS found that the entity met the standards for relief…
PLR 200718011: Late trust elections treated as inadvertent S termination
An S corporation shareholder died and left shares to three testamentary trusts, each with the same beneficiary. The beneficiary failed to file timely qualified subchapter S trust elections, so the…
PLR 200718010: Lubricating oil processing income qualifies under partnership rule
A business blended refined petroleum base oils with additives, packaged the resulting lubricating oils, and sold them to retailers and wholesale distributors. It asked whether income from this…
PLR 200718009: Processing petroleum base oil produces qualifying income
A business bought refined petroleum base oils, blended them with additives, and sold the resulting lubricating oils. It sought a ruling on whether income from that processing was qualifying income…
PLR 200718008: Nuclear decommissioning fund receives limited review waiver
A utility’s commission extended the period for collecting nuclear plant decommissioning costs from customers, triggering a required IRS review of the fund’s scheduled contribution amounts. The…
PLR 200718007: Petroleum base oil processing counts as qualifying income
A business processed refined petroleum base oils with additives into lubricating oils that it packaged and sold. The IRS ruled that income from this processing was qualifying income under section…
PLR 200718006: Lubricant processing income qualifies under section 7704
A business purchased refined petroleum base oils and processed them into packaged lubricating oils for sale. The IRS ruled that income from processing the oils was qualifying income under section…
PLR 200718005: Lubricating oil processing yields qualifying partnership income
A business bought highly refined petroleum base oils, blended and processed them into lubricating oils, and sold the finished products. It asked whether income from this processing qualified under…
CCA 200718004: Enterprise Zone gain ruling request withdrawn after adverse view
A partnership sought a ruling that gains from selling improved real estate in a D.C. Enterprise Zone qualified for the section 1400B zero percent capital gains rate. Chief Counsel informed the…
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.