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 200718003: Late dual consolidated loss elections receive extension
A corporate taxpayer used losses from foreign branches and other separate units to offset income on its U.S. consolidated return, but missed the required dual consolidated loss elections across…
PLR 200718002: County controlled hospital system can issue county bonds
A county formed a public corporation to operate its teaching hospital, provide indigent care, and conduct related education and research. The county remained its sole member and held extensive power…
PLR 200718001: Late consolidated group loss election receives extension
A consolidated group acquired two corporations from the same seller but did not file the election to treat both as meeting the loss subgroup parent requirement. The taxpayer had relied on a tax…
TAM 200717036: Credit union insurance commissions are taxable unrelated business income
A state-chartered credit union offered optional credit life and disability insurance to members who borrowed from it. It received commissions tied to the premiums and argued that the insurance…
TAM 200717035: Credit union insurance commissions are taxable unrelated business income
A state-chartered credit union offered optional credit life and disability insurance to members who borrowed from it. The IRS record says it made 237 loans in the year at issue, about 20 percent of…
TAM 200717034: Two credit union insurance programs create taxable unrelated business income
A state-chartered credit union sold two types of optional insurance to members: accidental death and dismemberment coverage, and credit life and disability coverage tied to loans. It received a 15…
TAM 200717033: Credit union receipts from two insurance programs are taxable
A state-chartered credit union offered members accidental death and dismemberment insurance and optional credit life and disability coverage on some loans. Its administrative allowance for the first…
TAM 200717032: Credit union credit insurance commissions are taxable
A state-chartered credit union offered optional credit life and disability insurance to members taking some types of loans. It received a commission equal to 20 percent of gross premiums, and about…
TAM 200717031: Credit union insurance and nonmember ATM fees are taxable
A state-chartered credit union earned income from accidental death and dismemberment insurance, optional loan insurance, and fees charged when nonmembers used its ATMs. It argued that the insurance…
TAM 200717030: Credit union income from two insurance programs is taxable
A state-chartered credit union sold accidental death and dismemberment insurance and optional credit life and disability insurance to members. It received an administrative allowance of 15 percent…
TAM 200717029: Credit union insurance programs yield unrelated business income
A state-chartered credit union offered accidental death and dismemberment insurance and optional credit life and disability insurance to its members. It received an administrative allowance from the…
PLR 200717028: Mental illness justifies late IRA rollover waiver
A taxpayer withdrew money from an IRA but missed the 60-day deadline to roll part of it into another IRA. She said a mental illness and an involuntary hospitalization prevented her from completing…
PLR 200717027: IRA rollover deadline waived after deposit into wrong account
A taxpayer intended to move money from one IRA to another, but a financial institution deposited her check into a taxable account instead. She learned of the mistake after the 60-day rollover period…
PLR 200717026: Divorce division of IRA permits smaller periodic payments
A taxpayer had been taking substantially equal periodic payments from an IRA before age 59½ to avoid the additional tax on early distributions. A divorce judgment required transferring half the IRA…
PLR 200717025: Illness and a bank deposit error justify a late IRA rollover
A taxpayer withdrew money from an IRA and intended to roll part of it into another IRA investment. He said a severe illness and medications reduced his ability to make financial decisions, and a…
PLR 200717024: Wrong rollover advice excuses one late IRA deposit
A taxpayer withdrew IRA funds while buying a home after a financial institution told him he had 90 days to redeposit them. The actual rollover deadline was 60 days. He tried to redeposit part of the…
PLR 200717023: Nonspouse beneficiary may transfer inherited plan funds to IRA
A plan participant died before a requested direct rollover from his employer's plan to his IRA was completed. He had named the same person, who was not his spouse, as beneficiary of both accounts.…
PLR 200717022: Nonspouse beneficiary may transfer inherited plan funds to IRA
A plan participant died before a requested direct rollover from his employer's plan to his IRA was completed. He had named the same person, who was not his spouse, as beneficiary of both accounts.…
PLR 200717021: Estate administrator's deposit qualifies as IRA rollover
An IRA owner requested distributions from two IRAs shortly before he died, intending to roll the money over within 60 days. His surviving spouse received the distribution check after his death and,…
PLR 200717020: Electric cooperative may add natural gas service
A tax exempt rural electric cooperative proposed selling natural gas to its members using other utilities' distribution facilities. The IRS ruled that this was a qualifying public utility service…
PLR 200717019: Hospital parent excludes medical office rent and loan interest from UBTI
A tax exempt health system parent leased hospital campus land to a controlled partnership that built and operated a medical office building. The parent also held a loan to the partnership. The IRS…
IRS determination 200717018: Charity exemption revoked after audit found no charitable activity
The IRS revoked a nonprofit's section 501(c)(3) exemption because it concluded the organization was not operating for a charitable or educational purpose. The attached examination report says its…
PLR 200717017: Dealer may identify qualifying debt hedges by aggregate risk
A securities dealer issued debt to finance mortgage assets and used derivatives to manage risks in its debt portfolio. It had previously identified hedges against specific debts, then recorded a…
PLR 200717016: Spouse may renounce one QTIP trust share with stated tax effects
After a decedent's estate elected the marital deduction for a QTIP trust, its trustees proposed dividing the trust into two shares. The surviving spouse would give up her entire interest in one…
PLR 200717015: Purchaser gets 45 days to file late section 338 election
A corporate purchaser acquired a foreign target and intended to make a section 338(g) election so the stock purchase would be treated as an asset acquisition for tax purposes. It missed the election…
PLR 200717014: Three stage corporate spin off receives specified tax rulings
A public company's affiliated group proposed separating two businesses through a contribution to a controlled corporation and three successive distributions of its stock. The IRS ruled that the…
PLR 200717013: Settlement fund receives mixed deduction and reporting rulings
A corporation funded a court supervised settlement of a customer class action for breach of contract. The IRS ruled that the fund was a qualified settlement fund and that prejudgment interest…
PLR 200717012: IRS grants tax rulings for a contribution and two corporate spin offs
A corporate group proposed moving subsidiary interests into a controlled corporation, distributing that corporation's stock to its parent, and then distributing another subsidiary's stock to the…
PLR 200717011: Foreign insurer receives more time to make two tax elections
A foreign insurance company missed the deadline to elect treatment as a domestic corporation under section 953(d) and the alternative tax for certain small insurers under section 831(b). Its parent…
PLR 200717010: Residential utility conservation payments are excluded from income
A tax exempt organization used funds collected by regulated electric and gas utilities to pay for residential energy efficiency and renewable energy measures. The IRS ruled that the described…
PLR 200717009: Contractor may revoke elections against bonus depreciation
A construction contractor elected against additional first year depreciation for eligible property in two tax years after its tax preparer advised that the returns showed losses. The contractor…
PLR 200717008: Steel fabricator may revoke elections against bonus depreciation
A steel fabrication and erection company elected against additional first year depreciation for property placed in service during two tax years. Its tax adviser had recommended the elections because…
PLR 200717007: Dividing family trust into three trusts preserves specified tax treatment
Trustees proposed dividing a trust created before September 25, 1985 into three equal trusts, one for each of the settlor's children and descendants, while changing trustee appointment rules. The…
PLR 200717006: Foreign entity gets more time to elect partnership status
A foreign entity said it intended to be classified as a partnership for federal tax purposes but inadvertently failed to file Form 8832. The IRS concluded that it met the requirements for late…
PLR 200717005: Foreign entity receives extension for partnership election
A foreign entity said it intended to be classified as a partnership for federal tax purposes but did not file Form 8832. The IRS concluded that it met the requirements for late election relief under…
PLR 200717004: Another foreign entity gets time for partnership election
A foreign entity said it intended to be classified as a partnership for federal tax purposes but inadvertently failed to file Form 8832. The IRS concluded that it met the requirements for late…
PLR 200717003: Foreign entity gets late partnership classification election
A foreign entity said it intended to be classified as a partnership for federal tax purposes but inadvertently failed to file Form 8832. The IRS concluded that it met the requirements for late…
PLR 200717002: Gift tax return errors do not defeat specified GST exemption allocations
Spouses made split gifts to trusts for their children and a grandchild, then filed gift tax returns with inconsistent generation-skipping transfer (GST) exemption entries. The IRS treated formula…
PLR 200717001: Nineteen way trust division preserves specified tax treatment
A court directed a trustee to divide a pre-1985 irrevocable family trust into nineteen trusts, one for each current income beneficiary, using each beneficiary's proportionate interest and a pro rata…
PLR 200716035: Sale of buildable lots does not end association's exemption or create UBTI
A section 501(c)(4) homeowners association planned to sell long held buildable lots to fund maintenance of its common areas. It said financial hardship prompted the sales and that it would make no…
PLR 200716034: Hospital owes unrelated business tax on interest from medical corporations
A tax exempt hospital and its parent lent money to affiliated medical corporations whose stock was held by physicians under restrictive agreements. The IRS found that the hospital beneficially…
PLR 200716033: Taxpayer gets more time to undo a Roth IRA conversion
A taxpayer converted a traditional IRA to a Roth IRA in 2005. An incorrect Form 1099-R led him to believe the conversion had not occurred; a corrected form arrived just before his filing deadline,…
PLR 200716032: Recalculating fixed IRA payments would trigger early distribution tax
A taxpayer began taking substantially equal periodic IRA payments at age 50, using the fixed amortization method with one annual amount. After his finances changed, he proposed recalculating the…
PLR 200716031: IRS gives mixed rulings on trust stock transferred to an ESOP
A charitable remainder trust was set to transfer company stock to an employee stock ownership plan after a beneficiary's death. The plan sought rulings on a proposed amendment, the stock's valuation…
PLR 200716030: Family death justifies late IRA rollover waiver
A taxpayer withdrew funds from an IRA while changing investments and put the money into a checking account. Her mother-in-law then became seriously ill and died, and the taxpayer did not move the…
PLR 200716029: Processing error supports waiver for withheld plan distribution
A participant asked his employer to transfer balances from three retirement plans directly to an IRA. A processing error caused the employer to send him a check for one plan's taxable balance and…
PLR 200716028: Mother's death supports late IRA rollover waiver
A taxpayer withdrew funds from an IRA while changing his investments and put them into a checking account. His mother became seriously ill and died during the 60 day rollover period. After handling…
PLR 200716027: ESOP may repay loan with stock redemption and allocate surplus shares
A company planned to terminate its employee stock ownership plan after a substantial drop in its workforce. It proposed redeeming enough unallocated company shares to repay an outstanding ESOP loan,…
PLR 200716026: Charity keeps exemption after adding a business league parent
A section 501(c)(3) membership charity created a section 501(c)(6) business league to handle member services and lobbying, with the new organization becoming its corporate parent. The organizations…
CCA 200716025: Withdrawn ruling request prompts tentative treaty analysis of seller payments
After a company withdrew its private letter ruling request, Chief Counsel notified an IRS field manager of its tentative view on payments to sellers resident in a foreign country. For individual…
PLR 200716024: Corporate separation receives mixed rulings on spin offs and deferred gain
A corporate group proposed two stock distributions and an asset contribution to separate businesses. The IRS treated a preferred stock redemption as rescinded, which meant the parent had not…
CCA 200716023: Railroad business is not a covered employer for railroad retirement tax
The Railroad Retirement Board reconsidered an earlier decision that treated a business as a covered railroad employer. The business clarified that its main purpose was to reduce coal transportation…
CCA 200716022: Business became a railroad retirement tax employer when operations began
The Railroad Retirement Board concluded that a business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act when it began operations. IRS Chief Counsel…
CCA 200716021: Railroad employer status began with first employee compensation
The Railroad Retirement Board found that a business became a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act when it first had employees. IRS Chief…
PLR 200716020: Former spouses get more time to allocate GST exemptions to a trust
Two taxpayers made gifts to a trust while married and elected to split some gifts, but did not allocate their generation-skipping transfer (GST) tax exemptions. They sought late allocations for…
PLR 200716019: Court settlement preserves a grandfathered trust's GST exemption
A family disputed how an old trust should distribute income after two beneficiaries died. A court approved their settlement, which would divide the trust into seven separate trusts and let…
PLR 200716018: Taxpayer gets more time for dual consolidated loss filings
A taxpayer reported dual consolidated losses from an interest in a foreign partnership on two years of U.S. returns. It failed to attach the required elections and agreements for both years and an…
PLR 200716017: Spin off of a subsidiary receives specified tax-free treatment
An S corporation proposed to distribute all stock of a wholly owned C corporation subsidiary to its two shareholders. The stated business purpose was to help the subsidiary retain a key employee,…
PLR 200716016: Merger qualifies as a reorganization with cash gain consequences
A nonstock corporation proposed to merge into a subsidiary of a publicly traded corporation. Its members could receive stock, cash, or a combination for their equity interests, while their trading…
PLR 200716015: REIT receives relief for a late taxable subsidiary election
A hotel-owning corporation intending to qualify as a real estate investment trust (REIT) leased properties to another corporation. A shared owner held more than 10 percent of the taxpayer's stock…
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.