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 200707037: Three governmental solar projects denied bond allocations
An applicant sought Clean Renewable Energy Bond allocations for three solar energy facilities listed in the appendix. IRC § 54 set an $800 million overall allocation limit and a $500 million limit…
PLR 200707036: One hydropower project receives bond allocation while another is denied
An applicant requested Clean Renewable Energy Bond authority for hydropower projects. The IRS approved an allocation for the project in Appendix A, finding it qualified under IRC § 54 and owned by a…
PLR 200707035: Government wind project denied bond allocation after funding cap is reached
An applicant requested Clean Renewable Energy Bond authority for a wind facility owned by a governmental borrower. IRC § 54 limited total allocations to $800 million and governmental allocations to…
PLR 200707034: Government biomass project denied bond allocation after funding cap is reached
An applicant sought a Clean Renewable Energy Bond allocation for a governmental project described as a closed-loop or open-loop biomass facility. IRC § 54 imposed an $800 million overall allocation…
PLR 200707033: Government open-loop biomass project denied bond allocation
An applicant requested Clean Renewable Energy Bond authority for an open-loop biomass facility owned by a governmental borrower. IRC § 54 capped total allocations at $800 million and allocations for…
PLR 200707032: Wind facility receives Clean Renewable Energy Bond allocation
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707031: Wind project receives bond allocation subject to issuance deadline
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707030: Wind facility receives bond authority under section 54
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707029: Two hydropower facilities receive renewable energy bond allocations
An applicant requested Clean Renewable Energy Bond authority for two qualified hydropower facilities. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by…
PLR 200707028: Two governmental solar projects denied bond allocations
An applicant requested Clean Renewable Energy Bond authority for two governmental solar energy facilities. IRC § 54 limited total allocations to $800 million and allocations for governmental…
PLR 200707027: Wind facility receives renewable energy bond allocation
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707026: Solar energy facility receives bond allocation
An applicant requested Clean Renewable Energy Bond authority for a solar energy facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified…
PLR 200707025: Solar project receives bond authority under section 54
An applicant requested Clean Renewable Energy Bond authority for a solar energy facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified…
PLR 200707024: Government project denied bond allocation with project details absent
An applicant requested Clean Renewable Energy Bond authority for a governmental renewable energy project. IRC § 54 limited total allocations to $800 million and allocations for governmental…
PLR 200707023: Government biomass facility denied bond allocation
An applicant requested Clean Renewable Energy Bond authority for a governmental open-loop biomass facility. IRC § 54 limited total allocations to $800 million and allocations for governmental…
PLR 200707022: Wind project receives renewable energy bond allocation
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707021: Fourteen solar projects receive bond allocations and one is denied
An applicant requested Clean Renewable Energy Bond allocations for solar energy facilities. The IRS approved allocations for the fourteen projects listed in Appendix A, finding them qualified under…
PLR 200707020: Government project denied bond authority after funding cap is reached
An applicant requested Clean Renewable Energy Bond authority for a governmental renewable energy project. IRC § 54 limited total allocations to $800 million and allocations for governmental…
PLR 200707019: Government project denied renewable bond allocation
An applicant requested Clean Renewable Energy Bond authority for a governmental renewable energy project. IRC § 54 limited total allocations to $800 million and allocations for governmental…
PLR 200707018: Wind facility receives CREB authority subject to statutory conditions
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707017: Nine governmental renewable energy projects denied bond allocations
An applicant requested Clean Renewable Energy Bond authority for eight governmental landfill gas facilities and one governmental open-loop biomass facility. IRC § 54 limited total allocations to…
PLR 200707016: Six solar projects receive bond allocations and two are denied
An applicant sought Clean Renewable Energy Bond authority for solar energy facilities. The IRS allocated bond authority for the six projects in Appendix A, finding them qualified under IRC § 54 and…
PLR 200707015: Seventeen solar projects receive renewable energy bond allocations
An applicant requested Clean Renewable Energy Bond authority for seventeen solar energy facilities. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by…
PLR 200707014: Four solar facilities receive bond allocations
An applicant requested Clean Renewable Energy Bond authority for four solar energy facilities. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by…
PLR 200707013: Government hydropower project denied renewable bond authority
An applicant requested Clean Renewable Energy Bond authority for a governmental hydropower facility. IRC § 54 limited total allocations to $800 million and allocations for governmental borrowers to…
PLR 200707012: Wind facility denied bond allocation after overall limit is exhausted
An applicant requested Clean Renewable Energy Bond authority for a wind facility. IRC § 54 imposed an $800 million overall allocation limit, with a separate $500 million limit for governmental…
PLR 200707011: Solar facility receives renewable energy bond allocation
An applicant requested Clean Renewable Energy Bond authority for a solar energy facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified…
PLR 200707010: Wind project receives Clean Renewable Energy Bond authority
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707009: Open-loop biomass facility receives bond allocation
An applicant requested Clean Renewable Energy Bond authority for an open-loop biomass facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by…
PLR 200707008: Wind facility receives renewable bond authority
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707007: Two solar facilities and one wind facility receive bond allocations
An applicant requested Clean Renewable Energy Bond authority for two solar energy facilities and one wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would…
PLR 200707006: Eleven wind and two hydropower facilities receive bond allocations
An applicant requested Clean Renewable Energy Bond authority for eleven wind facilities and two hydropower facilities. The IRS found the projects listed in Appendix A qualified under IRC § 54 and…
PLR 200707005: Wind facility receives Clean Renewable Energy Bond authority
An applicant requested Clean Renewable Energy Bond authority for a wind facility. The IRS found the projects listed in Appendix A qualified under IRC § 54 and would be owned by qualified borrowers.…
PLR 200707004: Sixty-two solar projects receive bond allocations and one is denied
An applicant sought Clean Renewable Energy Bond authority for solar energy facilities. The IRS approved allocations for the sixty-two projects in Appendix A, finding them qualified under IRC § 54…
PLR 200707003: Government open-loop biomass project denied renewable bond authority
An applicant requested Clean Renewable Energy Bond authority for a governmental open-loop biomass facility. IRC § 54 limited total allocations to $800 million and allocations for governmental…
CCA 200707002: Consolidated group cannot net its overpayment interest against a member's separate tax debt
Chief Counsel considered whether a consolidated corporate group could net interest on its income tax overpayment against a member's separate tax underpayment. One situation involved the member's…
CCA 200707001: Direct bank deposit by contractor does not require dealer's Form 8300 in stated scenario
Chief Counsel examined a used car dealer's reporting duty when an independent contractor deposited sale proceeds directly into the dealer's bank account. The deposit consisted of $6,000 in currency…
PLR 200706015: Foundation's educational grants qualify as distributions under stated safeguards
A private foundation proposed an educational grant program administered by its wholly owned, disregarded limited liability company. The program would fund individuals and associated organizations,…
OTHER 200706014: Gated homeowners association loses social-welfare tax exemption
The IRS revoked a homeowners association's exemption under IRC § 501(c)(4). The examination report found that a security gate prevented the general public from accessing the association's property.…
PLR 200706013: Pension plan denied longer amortization period because funding danger is not imminent
A multiemployer defined benefit pension plan requested more time to amortize its unfunded liabilities under IRC § 412(e). The plan had originally projected a funding deficiency in 2007. Actions by…
PLR 200706012: Late IRA rollover waiver granted after retiree mistakenly uses savings account
A 71-year-old IRA owner declined to renew a maturing certificate of deposit, believing the funds would remain within his IRA. The money instead went into an ordinary savings account at the same…
CCA 200706011: Insolvent subsidiary's deemed liquidation permits stock and debt losses
A corporate group claimed stock and bad-debt losses after a foreign subsidiary elected to become a disregarded entity. Chief Counsel concluded that the subsidiary was insolvent at the deemed…
CCA 200706010: Business ceases to be an employer under railroad retirement tax law
The Railroad Retirement Board advised the IRS that a business had ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. The business's identity and…
CCA 200706009: Railroad employer coverage ends with separate last-pay date noted
The Railroad Retirement Board advised that a business had ceased to be a covered employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
PLR 200706008: Governmental deferred compensation plan and deemed IRAs approved
A local governmental employer requested approval of an amended deferred compensation plan under section 457(b). The IRS ruled that the revised plan qualified and that deferred compensation and its…
PLR 200706007: Foreign joint venture consolidation qualifies as reorganizations
A U.S. corporate group sought to consolidate foreign joint venture holding companies and operating companies under one foreign holding company. The owners would contribute their stock and the…
PLR 200706006: Business spin-off receives corporate and shareholder nonrecognition rulings
A corporate group proposed separating two businesses by transferring one business and related subsidiary stock to a new corporation. It would distribute that corporation's two stock classes pro rata…
PLR 200706005: LLC receives more time to elect corporate tax classification
A domestic limited liability company intended to elect taxation as a corporation but missed the filing deadline. It requested an extension to make the election effective on its intended date. The…
PLR 200706004: Late S corporation election relief granted from incorporation
A corporation's shareholder intended S corporation treatment from the date of incorporation, but the election was not filed on time. The IRS found reasonable cause for the missed deadline and…
PLR 200706003: Foreign entity receives more time to elect disregarded status
A foreign entity represented that it was eligible to choose its federal tax classification. It intended to elect treatment as an entity disregarded as separate from its owner, but missed the filing…
PLR 200706002: Rural Telephone Bank liquidation income qualifies as patronage income
A rural telephone cooperative that had failed the section 501(c)(12) income test received a liquidation payment for Rural Telephone Bank stock. It had acquired the stock as a required part of…
PLR 200706001: Family timberland exchange qualifies despite subsequent related-party sale
A taxpayer exchanged her one-quarter undivided interest in inherited family timberland for full ownership of another parcel held by a family trust. The trust and her siblings then sold other land to…
PLR 200705036: Title-holding parent's wholly owned subsidiary treated as part of parent
An exempt title-holding corporation asked how its wholly owned real-property subsidiary would be treated for federal tax purposes. The IRS ruled that the subsidiary qualified under section…
PLR 200705035: Pension funding waiver denied after planned distress termination
A company requested a waiver of its pension plan's minimum funding standard for the year ending December 31, 2005. After a tentative denial and conference, the IRS sought revised actuarial…
PLR 200705034: IRA rollover waiver denied for deliberate withdrawal to buy employer stock
An employee withdrew IRA funds to buy stock in a financially troubled employer after an adviser said a withdrawal was the only option. The employee knew the distribution would be taxable and could…
PLR 200705033: Funding waiver denied for liquidating employer after no conference request
A company requested a waiver of its pension plan's minimum funding standard for the year ending March 31, 2005. It had filed for Chapter 11 protection, sold its assets, and entered liquidation,…
PLR 200705032: Spouse may roll over IRA proceeds distributed through marital trust
A surviving spouse had an unlimited right to withdraw a marital trust's assets, including four IRAs left by her husband. Trustees had inadvertently omitted the IRAs when distributing the other trust…
PLR 200705031: IRA investment settlement qualifies for restorative payment rollover relief
A widow received settlement proceeds after she and her deceased husband complained about allegedly unsuitable investments in his IRA. She deposited the proceeds in non-IRA accounts after a financial…
PLR 200705030: Liquidating insurer retains exemption under temporary transition rule
A court-appointed receiver asked whether an insolvent insurer could retain its tax exemption while making final creditor distributions and closing its estate. The insurer had transferred its life…
CCA 200705029: Pro forma legislative meetings do not establish deductible legislative days
Chief Counsel considered which days count for a state legislator's elected travel-expense treatment under section 162(h). A legislature is in session only when it sits in an organized capacity and…
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.