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 200636021: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636020: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636019: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636018: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636017: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636016: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636015: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636014: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636013: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636012: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636011: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636010: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636009: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636008: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636007: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636006: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636005: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636004: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636003: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636002: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636001: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
Other 200635018: Cancer care review group denied charitable tax exemption
A nonprofit formed by two for profit medical practices sought recognition as a tax exempt charity. It proposed to coordinate review of cancer treatment plans, initially for patients of a for profit…
PLR 200635017: Family asset options and charitable trusts avoid self-dealing rules
Several family members planned to leave nonvoting interests in investment companies to charitable trusts. Other family members held options to buy specified assets, including notes or nonvoting…
PLR 200635016: Family asset options and charitable trusts avoid self-dealing rules
Several family members planned to leave nonvoting interests in investment companies to charitable trusts. Other family members held options to buy specified assets, including notes or nonvoting…
PLR 200635015: Family asset options and charitable trusts avoid self-dealing rules
Several family members planned to leave nonvoting interests in investment companies to charitable trusts. Other family members held options to buy specified assets, including notes or nonvoting…
PLR 200635014: Foundation receives advance ruling on public charity transition
A private foundation that supported local charitable projects sought an advance ruling on its plan to become a publicly supported charity. It proposed broader fundraising, including member appeals,…
PLR 200635013: Sister may receive inherited plan benefits through nontransferable annuities
An unmarried participant died before her required distribution starting date, leaving benefits in two retirement plans to her sister. The plans proposed to buy separate nontransferable fixed or…
PLR 200635012: IRS waives late IRA rollover deadline after agent withdraws from wrong annuity
A 78-year-old taxpayer asked for relief after a financial institution's agent withdrew money from her IRA annuity when she thought she was using a non-IRA annuity. Her impaired vision kept her from…
PLR 200635011: Company receives conditional minimum funding waiver for pension plan
The IRS granted a company a conditional waiver of its pension plan's minimum funding standard for the plan year beginning April 1, 2004. The company had suffered severe financial difficulties and a…
TAM 200635010: Mixed service costs need a separate reasonable allocation between property types
A company used the simplified service cost method to calculate its total mixed service costs that had to be capitalized, then split that total between two types of property using their relative…
PLR 200635009: Public utility authority is a political subdivision and subsidiary bonds qualify as issued on its behalf
A state-created authority that produces and transmits electricity asked whether it was a political subdivision for purposes of § 103 and whether bonds issued by a planned subsidiary would count as…
PLR 200635008: Treasury lock and interest rate swap income qualifies for partnership income test
A publicly traded partnership in the oil and gas business used treasury locks and interest rate swaps to manage borrowing costs. It asked whether income from those transactions counted as qualifying…
PLR 200635007: Company gets 60 days to file dual consolidated loss elections
A corporation included losses from a foreign branch in its U.S. returns for five tax years but failed to file the associated dual consolidated loss elections and agreements. Its tax staff had not…
PLR 200635006: Purchaser gets extension to file section 338 election for foreign target
A corporate purchaser intended to elect asset purchase treatment under § 338(g) for its acquisition of a foreign target and its subsidiaries, but could not show that a valid election had been filed…
PLR 200635005: Utility cannot credit customers with tax reserves tied to sold generation assets
A regulated utility sold its electric generating assets and asked how tax related balances tied to those assets could be treated in customer rates. The IRS ruled that leaving unamortized accumulated…
PLR 200635004: Utility cannot keep amortizing tax credits for sold generation assets into rates
A regulated utility sold its electric generating assets and asked whether it could keep using tax related balances from those assets to reduce customer rates. The IRS ruled that keeping unamortized…
PLR 200635003: Parent gets more time to elect recognition of subsidiary stock sale loss
A parent corporation sold part of a subsidiary's stock to an unrelated buyer at a loss, but its consolidated return omitted the statement needed to elect the limited loss recognition allowed by a…
PLR 200635002: Tribal authority qualifies as political subdivision and owes no federal income tax
A tribal government created an authority to oversee and finance certain tribal businesses and delegated taxing powers to it. After consulting the Department of the Interior, the IRS concluded that…
PLR 200635001: IRS waives life insurance test failures if excess premiums are refunded
Two variable life insurance contracts exceeded their actual guideline premium limits after an administrator changed insureds' risk classifications on only two of three required screens. The…
PLR 200634074: Tool maker receives conditional pension funding waiver
A manufacturer of steel cutting tools sought relief from its pension plan's minimum funding standard for the plan year ending June 30, 2005. It reported declining sales, layoffs, lower cost…
PLR 200634073: IRS denies late IRA rollover waiver for mistaken 90-day deadline
A taxpayer withdrew the balance of an IRA, intending to move it later to an IRA with a better return. When he tried to redeposit the check, the bank told him the 60-day rollover deadline had passed.…
PLR 200634072: Medication related memory lapses justify late IRA rollover waiver
A taxpayer planned to move an IRA distribution into a certificate of deposit held in another IRA. Medication side effects caused periodic memory lapses, and she missed the 60-day deadline, which…
PLR 200634071: Incorrect IRA custodian assurance leads to late rollover waiver
A taxpayer wired an IRA distribution to a company after its representative said the money would go into an IRA account. The company was not an approved IRA custodian and placed the money in a…
PLR 200634070: Inherited IRA trusts qualify, but beneficiaries cannot use separate shares
An IRA owner died before his required distribution starting date. His named primary beneficiary had predeceased him, so the IRA passed to a trust for his son and two grandsons through three…
PLR 200634069: Inherited IRA trusts qualify, but beneficiaries cannot use separate shares
An IRA owner died before his required distribution starting date. His named primary beneficiary had predeceased him, so the IRA passed to a trust for his son and two grandsons through three…
PLR 200634068: Inherited IRA trusts qualify, but beneficiaries cannot use separate shares
An IRA owner died before his required distribution starting date. His named primary beneficiary had predeceased him, so the IRA passed to a trust for his son and two grandsons through three…
PLR 200634067: Mistaken IRA withdrawal does not qualify for rollover deadline waiver
A retiree withdrew money from his IRA after an adviser incorrectly said he could satisfy both his retirement plan and IRA required minimum distributions from the IRA. After learning that he also…
PLR 200634066: Conflicting plan notices support rollover deadline waiver
A worker received conflicting and delayed notices about the termination of his employer's retirement plan and the choices for distributing his account. He returned an initial distribution check and…
PLR 200634065: Surviving spouse may roll over IRA proceeds paid through estate
An IRA owner died without a recorded beneficiary designation, so the account agreement made her estate the beneficiary. Her surviving spouse was the estate's sole executor and residuary beneficiary.…
PLR 200634064: Wrong online account qualifies for rollover deadline waiver
A worker instructed his spouse to open a rollover IRA while he was working abroad. Confusing online instructions led her to open an ordinary account, and his retirement plan distribution was sent…
PLR 200634063: Pension funding waiver security condition modified
The IRS had granted a pension plan a conditional waiver of its minimum funding standard for the plan year ending April 30, 2004. This letter changes one condition of that earlier ruling. It requires…
PLR 200634062: IRA withdrawal used to help sister does not receive rollover extension
An IRA owner withdrew money to help his sister avoid foreclosure on her house. He could not recover and redeposit the money within the 60-day rollover period. The IRS denied his request for more…
PLR 200634061: Merger related ESOP loan repayment preserves exemption
A company merged with another company and had to terminate its employee stock ownership plan, or ESOP. The plan would use cash from the merger and proceeds from selling some unallocated stock to…
PLR 200634060: House deposit from IRA does not qualify for rollover extension
A taxpayer withdrew IRA money for a deposit on a house while relocating for work. He knew the money had to be returned within 60 days but did not have sufficient funds by then. The IRS denied a…
PLR 200634059: Employer stock tax treatment depends on when a plan pays the full balance
An employer asked whether four people receiving stock from its combined employee stock ownership and 401(k) plan could exclude the stock's net unrealized appreciation from income. The IRS allowed…
PLR 200634058: Health problems justify more time to roll over a retirement plan payout
A former plan participant received a retirement plan distribution in 2004 and missed the 60 day deadline to roll it into an IRA. She said chronic back pain, severe depression, and medication…
PLR 200634057: Surviving spouse may roll inherited plan balance into her own account
A widow inherited her husband's balance in a qualified pension plan in which she also participated. She wanted to move the inherited balance directly into her own account in that same plan, after…
PLR 200634056: Regret over an IRA withdrawal does not justify a rollover extension
A taxpayer took stock out of his IRA and placed it in a personal account outside the IRA. He missed the 60 day rollover period after misunderstanding the withdrawal rules and later regretting the…
PLR 200634055: Sunday rollover deadline qualifies for an IRA extension
A taxpayer planned to roll part of an IRA withdrawal into another IRA, but the 60th day fell on a Sunday when the receiving credit union was closed. The taxpayer attempted the deposit on the next…
PLR 200634054: Pension amendment qualifies for exceptions during bankruptcy
A company amended its defined benefit pension plan while its parent was in Chapter 11 bankruptcy, before the parent's reorganization took effect. Federal tax and pension law generally restrict…
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.