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.

42,150 determinations and counting · Newest release October 16, 2026
42,150 determinations

No determinations match these filters

Try fewer or different words, check the spelling, or clear the filters to browse everything.

DET

Determination 200708056: Trash combustion project denied renewable energy bond authority

An issuer requested Clean Renewable Energy Bond authority for a trash combustion facility. The IRS denied the allocation because the application failed to demonstrate that one or more requirements…

200708056·February 23, 2007
Denied
DET

Determination 200708055: Fourteen landfill gas allocations approved, another denied

An issuer requested Clean Renewable Energy Bond authority for landfill gas projects. The IRS allocated authority under IRC § 54 for the fourteen facilities in Appendix A. It denied an allocation for…

200708055·February 23, 2007
Mixed outcome
PLR

PLR 200708054: Land exchange and trust division preserve tax protections

A trustee proposed exchanging business real estate with related family trusts and then dividing a testamentary trust between two family branches. The will directed the trustee to create separate…

200708054·February 23, 2007
Approved
DET

Determination 200708053: Wind facility awarded renewable energy bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708053·February 23, 2007
Approved
DET

Determination 200708052: IRS approves wind facility bond allocation

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708052·February 23, 2007
Approved
DET

Determination 200708051: Clean renewable energy bond authority granted for wind facility

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708051·February 23, 2007
Approved
DET

Determination 200708050: Wind facility receives bond issuance allocation

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708050·February 23, 2007
Approved
DET

Determination 200708049: IRS allocates clean renewable bond authority for wind facility

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708049·February 23, 2007
Approved
DET

Determination 200708048: Wind project approved for clean renewable energy bonds

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708048·February 23, 2007
Approved
DET

Determination 200708047: Wind facility granted renewable energy bond allocation

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708047·February 23, 2007
Approved
DET

Determination 200708046: Four solar projects receive renewable energy bond allocations

An issuer applied for authority to issue Clean Renewable Energy Bonds for four solar energy facilities. The IRS determined that the projects in Appendix A qualified under IRC § 54 and allocated bond…

200708046·February 23, 2007
Approved
DET

Determination 200708045: Wind facility approved for clean renewable bond financing

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708045·February 23, 2007
Approved
DET

Determination 200708044: Bond authority granted for wind energy facility

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708044·February 23, 2007
Approved
DET

Determination 200708043: Nine solar allocations approved and three denied

An issuer applied for Clean Renewable Energy Bond authority for solar energy facilities. The IRS allocated authority under IRC § 54 for the nine projects in Appendix A. It denied allocations for the…

200708043·February 23, 2007
Mixed outcome
DET

Determination 200708042: Four solar allocations granted and two denied after governmental limit exhausted

An issuer requested Clean Renewable Energy Bond authority for solar energy facilities. The IRS approved allocations under IRC § 54 for the four projects in Appendix A. It denied allocations for the…

200708042·February 23, 2007
Mixed outcome
DET

Determination 200708041: Wind allocation denied after governmental bond limit exhausted

An issuer requested Clean Renewable Energy Bond authority for a wind facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental projects…

200708041·February 23, 2007
Denied
DET

Determination 200708040: Wind facility receives clean renewable energy bond allocation

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708040·February 23, 2007
Approved
DET

Determination 200708039: Landfill gas bond request denied after governmental limit exhausted

An issuer requested Clean Renewable Energy Bond authority for a landfill gas facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental…

200708039·February 23, 2007
Denied
DET

Determination 200708038: Governmental wind allocation denied after smaller requests use limit

An issuer requested Clean Renewable Energy Bond authority for a wind facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental projects…

200708038·February 23, 2007
Denied
DET

Determination 200708037: Solar facility approved for renewable energy bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a solar energy facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond…

200708037·February 23, 2007
Approved
DET

Determination 200708036: Hydropower allocation denied after governmental limit exhausted

An issuer requested Clean Renewable Energy Bond authority for a hydropower facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental…

200708036·February 23, 2007
Denied
DET

Determination 200708035: Landfill gas allocation denied because governmental authority was exhausted

An issuer requested Clean Renewable Energy Bond authority for a landfill gas facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental…

200708035·February 23, 2007
Denied
DET

Determination 200708034: Five wind allocations denied after governmental limit exhausted

An issuer requested Clean Renewable Energy Bond authority for five wind facilities owned by governmental borrowers. The IRS denied allocations for all five because the $500 million limit for…

200708034·February 23, 2007
Denied
DET

Determination 200708033: Biomass allocation denied after governmental bond limit exhausted

An issuer requested Clean Renewable Energy Bond authority for an open-loop biomass facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for…

200708033·February 23, 2007
Denied
DET

Determination 200708032: Governmental landfill gas request denied after allocation limit exhausted

An issuer requested Clean Renewable Energy Bond authority for a landfill gas facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental…

200708032·February 23, 2007
Denied
DET

Determination 200708031: IRS approves renewable energy bond authority for wind facility

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708031·February 23, 2007
Approved
DET

Determination 200708030: Reduced hydropower bond allocation proposed pending issuer response

An issuer sought Clean Renewable Energy Bond authority for a hydropower facility owned by a governmental borrower. The IRS found the project qualified under IRC § 54 but proposed a smaller…

200708030·February 23, 2007
Mixed outcome
DET

Determination 200708029: Trash combustion allocation denied after governmental bond limit exhausted

An issuer requested Clean Renewable Energy Bond authority for a trash combustion facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for…

200708029·February 23, 2007
Denied
DET

Determination 200708028: Solar energy facility receives clean renewable bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a solar energy facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond…

200708028·February 23, 2007
Approved
DET

Determination 200708027: Wind facility allocated renewable energy bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708027·February 23, 2007
Approved
DET

Determination 200708026: Renewable energy bond allocation approved for wind facility

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708026·February 23, 2007
Approved
DET

Determination 200708025: Wind facility awarded clean renewable energy bond allocation

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708025·February 23, 2007
Approved
DET

Determination 200708024: Hydropower facility granted clean renewable energy bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a hydropower facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond…

200708024·February 23, 2007
Approved
DET

Determination 200708023: Wind project granted renewable energy bond authority

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708023·February 23, 2007
Approved
DET

Determination 200708022: Landfill gas and wind projects granted renewable energy bond allocations

An issuer applied for authority to issue Clean Renewable Energy Bonds for a landfill gas facility and a wind facility. The IRS determined that the projects in Appendix A qualified under IRC § 54 and…

200708022·February 23, 2007
Approved
DET

Determination 200708021: Clean renewable bond allocation approved for wind project

An issuer applied for authority to issue Clean Renewable Energy Bonds for a wind facility. The IRS determined that the project in Appendix A qualified under IRC § 54 and allocated bond authority for…

200708021·February 23, 2007
Approved
DET

Determination 200708020: Solar allocation denied after governmental bond authority exhausted

An issuer requested Clean Renewable Energy Bond authority for a solar energy facility owned by a governmental borrower. The IRS denied an allocation because the $500 million limit for governmental…

200708020·February 23, 2007
Denied
PLR

PLR 200708019: Stock exchange followed by QSub election qualifies as reorganization

An S corporation proposed exchanging its shares for a target corporation’s shares and then electing to treat the target as a qualified subchapter S subsidiary (QSub). Shareholders unwilling or…

200708019·February 23, 2007
Approved
PLR

PLR 200708018: Management stock options and repurchase agreement do not create second stock class

A company sought approval of a nonqualified stock option plan designed to broaden ownership among long-term management. The options were nontransferable, had no readily ascertainable value when…

200708018·February 23, 2007
Approved
PLR

PLR 200708017: Supplemental ruling approves internal distributions before spin-off and merger

A corporate group sought a supplemental ruling on changes to restructuring steps preceding a spin-off and merger previously addressed by the IRS. The changes included revised debt-exchange…

200708017·February 23, 2007
Approved
PLR

PLR 200708016: Parent restructuring and spin-off approved with cash and acquisition rules

A public corporate group proposed separating two businesses while bringing outside investors into the business retained by the new parent. The IRS ruled that the parent merger and LLC conversion…

200708016·February 23, 2007
Approved
PLR

PLR 200708015: Subsidiary restructuring and public spin-off qualify for nonrecognition

A publicly traded corporate group proposed reorganizing its subsidiaries and spinning off one business to its public shareholders. The IRS ruled that a subsidiary’s conversion to a disregarded…

200708015·February 23, 2007
Approved
PLR

PLR 200708014: Late tax-year change application treated as timely filed

An S corporation asked the IRS to treat its late Form 1128 for a change of tax year as timely filed. The filing was missed because of unforeseen events beyond the taxpayer’s control. The IRS found…

200708014·February 23, 2007
Approved
PLR

PLR 200708013: S corporation receives relief for late tax-year change filing

An S corporation asked the IRS to treat its late Form 1128 for a change of tax year as timely filed. The filing was missed because of unforeseen events beyond the taxpayer’s control. The IRS found…

200708013·February 23, 2007
Approved
PLR

PLR 200708012: Employee split-off qualifies as reorganization, with tax on cash redemptions

A parent company proposed separating a subsidiary so the subsidiary could regain small-business benefits under government contracting rules. Eligible subsidiary employees and management would…

200708012·February 23, 2007
Approved
PLR

PLR 200708011: Insurance investment portfolio can elect partnership status without public trading classification

Two life insurers requested entity-classification rulings for an investment portfolio supporting their variable insurance contracts. The insurers owned the portfolio shares for federal tax purposes,…

200708011·February 23, 2007
Approved
PLR

PLR 200708010: Variable-contract investment portfolio qualifies for nonpublic partnership treatment

Two life insurers requested entity-classification rulings for an investment portfolio supporting their variable insurance contracts. The insurers owned the portfolio shares for federal tax purposes,…

200708010·February 23, 2007
Approved
PLR

PLR 200708009: Corporate group receives 45 days to elect consolidated return filing

A corporate parent failed to make a timely election to file a consolidated federal income tax return with its subsidiaries. It had reasonably relied on a qualified tax professional and sought relief…

200708009·February 23, 2007
Approved
PLR

PLR 200708008: Coal synthetic-fuel credit rulings survive reagent and ownership changes

A partnership producing synthetic fuel from coal sought confirmation of earlier rulings after proposing alternative reagents, changing indirect ownership, and amending operating and financing…

200708008·February 23, 2007
Approved
PLR

PLR 200708007: Coal synthetic-fuel credit rulings survive reagent and ownership changes

A partnership producing synthetic fuel from coal sought confirmation of earlier rulings after proposing alternative reagents, changing indirect ownership, and amending operating and financing…

200708007·February 23, 2007
Approved
PLR

PLR 200708006: Mandatory leave contributions fund tax-free retiree medical benefits

An employer proposed a trust to pay medical expenses for eligible retirees and their spouses and dependents. Funding included discretionary employer contributions and employer-determined amounts…

200708006·February 23, 2007
Approved
PLR

PLR 200708005: Relocation and alternative reagents preserve synthetic-fuel credit rulings

A partnership asked the IRS to reconfirm synthetic-fuel credit rulings after moving its coal-processing facility and proposing alternative chemical reagents. The IRS reissued the rulings that the…

200708005·February 23, 2007
Approved
PLR

PLR 200708004: Foreign entity receives 60 days to elect partnership classification

A foreign entity inadvertently failed to file Form 8832 electing partnership treatment from its formation date. It represented that it was eligible to make that classification election. The IRS…

200708004·February 23, 2007
Approved
CCA

CCA 200708003: Minnesota military-service credit refunds generally qualify as gifts

Chief Counsel considered the federal tax treatment of Minnesota's military-service credit for residents serving in designated combat and hazardous-duty areas. The part applied against state tax…

200708003·February 23, 2007
Advice
PLR

PLR 200708002: Transferable vested stock options remain untaxed at grant

A taxpayer proposed nonstatutory stock options allowing holders to sell vested options to unrelated buyers for cash. It asked whether that transfer right would make the options taxable when granted.…

200708002·February 23, 2007
Approved
PLR

PLR 200708001: Estate may split marital trust and make late reverse QTIP election

An estate's tax preparer had omitted a reverse QTIP election and failed to arrange a marital-trust division needed to use the decedent's remaining generation-skipping transfer tax exemption. The…

200708001·February 23, 2007
Approved
DET

Determination 200707161: Foundation loses exemption after paying private television expenses

The IRS revoked a private foundation's tax exemption after finding that it operated for private interests and allowed its earnings to benefit an individual. The examination report described payments…

200707161·February 16, 2007
Revocation
PLR

PLR 200707160: IRA rollover waiver denied for retirement-home purchase

An IRA owner withdrew funds to buy a retirement home and expected sales of other properties to provide money for a rollover within 60 days. When those sales did not occur, the owner sought a credit…

200707160·February 16, 2007
Denied
PLR

PLR 200707159: Surviving spouse may roll over trust-held retirement funds after adviser error

A surviving spouse was sole trustee of a trust named as beneficiary of the deceased spouse's IRA and qualified retirement plan. The trust terms and state law required allocation to the marital…

200707159·February 16, 2007
Approved
PLR

PLR 200707158: Court-approved IRA beneficiary settlement avoids gift and distribution tax

An estate dispute alleged that an attorney-in-fact had improperly redirected a decedent's assets to himself and his children. A court-approved settlement reformed the IRA beneficiary designation and…

200707158·February 16, 2007
Approved

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.