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 200622057: IRS extends deadline to secure pension funding waivers
A taxpayer had received minimum funding waivers for six pension plans, covering seven plan years. The earlier ruling letters required the taxpayer to secure those waivers in a way acceptable to the…
PLR 200622056: Bank error earns IRA owner more time to complete rollover
A 77-year-old IRA owner asked her bank to deposit an IRA distribution into a new IRA. A bank employee instead placed the money in a non IRA account, and she did not discover the error until…
IRS 200622055: Financial education group denied tax exempt status
An organization sought recognition as a section 501(c)(3) charity for financial education, seminars, and consulting. The IRS found that its stated purposes could be carried out commercially and that…
PLR 200622054: Government affiliate excused from filing annual Form 990
A section 501(c)(6) organization had previously received an IRS ruling treating its income as excluded under section 115 and recognizing its governmental ties for employment tax and charitable…
PLR 200622053: IRS waives excise taxes on a pension plan liquidity shortfall
A nonprofit health care provider's pension plan had a liquidity shortfall after employee departures led to unusually many lump sum payments. Management changes and a switch to a new actuary delayed…
TAM 200622052: Social club loses exemption for lot rentals and business activity
A lakeside recreation club leased residential lots to members, maintained roads and other residential services, and sold fuel to nonmembers. The IRS concluded that each of those activities supplied…
PLR 200622051: Pediatric hospital reorganization preserves tax exemptions
Four related tax exempt organizations proposed to simplify their structure by dissolving a management organization and a pediatric home health provider and transferring their assets and functions to…
PLR 200622050: Pediatric hospital reorganization preserves tax exemptions
Four related tax exempt organizations proposed to simplify their structure by dissolving a management organization and a pediatric home health provider and transferring their assets and functions to…
PLR 200622049: Pediatric hospital reorganization preserves tax exemptions
Four related tax exempt organizations proposed to simplify their structure by dissolving a management organization and a pediatric home health provider and transferring their assets and functions to…
TAM 200622048: Domestic assembly prevents component from qualifying as export property
A domestic manufacturer sold a component to another company, which installed it in a final product in the United States before delivering that product overseas. The manufacturer sought to treat its…
TAM 200622047: IRS analyzes proceeds and maturity rules for mortgage bond refunding
An issuer used new bonds to refund older tax exempt bonds that had financed residential mortgages, while some proceeds of the old bonds remained unspent. The IRS said those unspent amounts were not…
TAM 200622046: Stock warrant value was income when granted
A telecommunications company received a warrant to buy another company's shares as part of a business agreement. The warrant was exercisable after a waiting period, but its value could be determined…
CCA 200622045: Acquisition interest deductions take priority in classifying a net operating loss
A corporation claimed a net operating loss after a stock acquisition that qualified as a corporate equity reduction transaction. It had interest deductions tied to the acquisition and deductions…
CCA 200622044: Foreign tax credit limited when withholding taxes offset a separate levy
A U.S. corporation's U.K. subsidiary paid foreign dividend withholding taxes and used some of them as credits against a U.K. levy on substitute dividend payments. The IRS concluded that the separate…
CCA 200622043: Government pension plan qualifies, but employee participation still matters for FICA
A government employer asked whether its police pension plan met the retirement system requirement for the Social Security portion of FICA. The IRS said the plan's benefit formula satisfied the…
PLR 200622042: Replacing trust advisors preserved tax treatment
A trust created under a decedent's will planned to replace all three members of its advisory committee through resignations and appointments allowed by the will. The trust sought rulings on…
PLR 200622041: Late S corporation election accepted if filed within 60 days
A corporation intended to elect S corporation status from its incorporation date but did not file Form 2553 on time. It asked the IRS for relief from the election deadline. The IRS found reasonable…
PLR 200622040: Corporation granted 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 delay under IRC § 1362(b)(5). It…
PLR 200622039: Late S election granted relief for intended effective date
A corporation intended to elect S corporation status from a specified date after its incorporation but missed the filing deadline. The IRS found reasonable cause for the late election under IRC §…
PLR 200622038: Business separation qualified for specified reorganization treatment
An S corporation planned to put one of its two businesses into a new corporation and distribute the new corporation's stock to its shareholders. The IRS ruled that the steps would constitute a…
PLR 200622037: Missed S election deadline excused with timely follow up filing
A corporation meant to elect S corporation status from its incorporation date but did not file Form 2553 by the deadline. The IRS found reasonable cause for the late election under IRC § 1362(b)(5).…
PLR 200622036: S corporation election treated as timely if filed within 60 days
A corporation's president and sole shareholder said the company had intended to elect S corporation status from its incorporation date, but no Form 2553 was filed on time. The IRS granted relief for…
PLR 200622035: Shareholder split qualified for specified reorganization treatment
Shareholders of an S corporation disagreed over how to run its business. The company planned to give one shareholder all the stock of a subsidiary in exchange for that shareholder's stock in the…
PLR 200622034: Late S election relief granted for intended date
A corporation's shareholder intended the company to be an S corporation from a specified date after incorporation, but the election was filed late. The IRS found reasonable cause for the delay and…
PLR 200622033: Late S corporation election treated as timely with amended returns
A corporation's shareholders intended it to elect S corporation status for a specified tax year, but its Form 2553 was filed late. The IRS found reasonable cause for the delay and granted relief…
PLR 200622032: More time to allocate a consolidated section 382 limit to a subsidiary
A parent corporation's consolidated group had tax attributes subject to an annual limit after an ownership change. When the group ended, it failed to elect to allocate part of that limit to a…
PLR 200622031: More time for controlled group value restoration election
After a corporate ownership change, a parent and a related life insurance company missed the deadline to elect to restore part of the company's value to the parent for purposes of the limit on using…
PLR 200622030: Gift tax return substantially complied with GST exemption allocation rules
A spouse consented to treat half of her husband's gifts to four trusts as her own. Their return preparer listed an allocation of her generation-skipping transfer (GST) tax exemption and showed a…
PLR 200622029: Donor's return substantially complied with GST exemption allocation rules
A donor made gifts to four trusts, and his spouse agreed to treat half of those gifts as hers. Their return preparer listed an allocation of the donor's generation-skipping transfer (GST) tax…
PLR 200622028: More time to request waiver for returning consolidated group member
A corporation left its parent's consolidated tax group, was bought back, and merged into another group member. The parent omitted from its consolidated return the statement needed to request a…
PLR 200622027: Bankruptcy court approval satisfies compensation plan shareholder vote rule
A corporation in Chapter 11 bankruptcy had two incentive compensation plans for senior managers. The plans had previously been approved by shareholders, but their material terms were due for renewed…
PLR 200622026: More time for interest charge DISC election after postage error
A newly formed corporation intended to elect interest charge DISC status for its first tax year. It gave a signed Form 4876-A to its mailroom within the filing period, but the Postal Service…
PLR 200622025: S corporation merger into an LLC qualifies as a change in form
An S corporation planned to merge into a newly formed limited liability company owned in the same proportions by its three shareholders. The LLC would elect to be taxed as a corporation from its…
PLR 200622024: Late application to change tax year treated as timely
A taxpayer filed Form 1128 late to change its annual tax year from one ending March 31 to one ending on the last Sunday in April. The application was late because of an error or misunderstanding,…
PLR 200622023: Late S election relief for a newly incorporated business
A corporation's sole shareholder intended it to be an S corporation from the date it was incorporated, but its Form 2553 was not filed on time. The IRS found reasonable cause for the delay and…
PLR 200622022: Investment fund merger qualifies as C reorganization with different shareholder results
A regulated investment company planned to transfer substantially all of its assets and liabilities to another fund for shares, distribute those shares to its investors, and liquidate. A shareholder…
PLR 200622021: Investment fund merger qualifies as C reorganization with different shareholder results
A regulated investment company planned to transfer substantially all of its assets and liabilities to another fund for shares, distribute those shares to its investors, and liquidate. A shareholder…
PLR 200622020: Cash payout from annuity cannot be rolled into a tax-free exchange
A revocable trust held a nonqualified annuity for a taxpayer and her spouse. After the spouse died, the insurer refused to exchange it for an annuity in the taxpayer's name and instead paid the full…
PLR 200622019: State dissolution and reincorporation do not end S corporation status
A corporation that had elected S corporation status learned that its state had administratively dissolved it in an earlier year. It promptly took steps to reincorporate and asked whether its S…
PLR 200622018: Late S election effective from incorporation
A corporation intended to be treated as an S corporation from the date it was incorporated, but did not file its election on time. The IRS found reasonable cause for the delay and granted relief…
PLR 200622017: Foreign insurer gets more time to elect domestic tax treatment
A foreign captive insurance company had not elected under IRC § 953(d) to be treated as a domestic corporation for U.S. tax purposes. It said it had not realized that later changes to the controlled…
PLR 200622016: More time to file dual consolidated loss rebuttal documents
A U.S. consolidated group had used dual consolidated losses of a foreign disregarded entity. After that entity transferred most of its assets and liabilities to another foreign corporation, the…
PLR 200622015: Attached notices preserve GST exemption allocation despite form omission
A taxpayer transferred a limited partnership interest to a trust for descendants, and the taxpayer and spouse elected to split the gift. Both timely filed gift tax returns with notices allocating…
PLR 200622014: S election may take effect from incorporation despite missing timely filing
A corporation's president and sole shareholder said he intended S corporation treatment from its incorporation date, but the IRS had no record of a timely Form 2553. The IRS found reasonable cause…
PLR 200622013: Bankrupt company may use known ownership information for section 382 testing
A company exchanged debt for stock in a bankruptcy reorganization and needed to track later ownership shifts that could limit its use of net operating losses under IRC § 382. Its unregistered stock…
PLR 200622012: Late S election accepted from intended incorporation date
A corporation's shareholder intended S corporation treatment from its incorporation date, but the corporation missed the election deadline. The IRS found reasonable cause for the late filing and…
PLR 200622011: Relative share value fixed for section 382 ownership tests
A loss corporation had common and preferred shares whose relative values changed after an ownership change, even without corresponding stock transfers. It asked how to calculate five-percent…
PLR 200622010: Replacing trust advisors leaves GST exemption and tax interests intact
A trust created under a will that became irrevocable before September 25, 1985, planned to replace its advisory committee members through the procedure in the will. The IRS found the changes…
PLR 200622009: Replacing trust advisors leaves GST exemption and tax interests intact
A trust created under a will that became irrevocable before September 25, 1985, planned to replace its advisory committee members through the procedure in the will. The IRS found the changes…
PLR 200622008: Late S election accepted from intended incorporation date
A corporation's shareholders intended S corporation treatment from its incorporation date, but the corporation missed the election deadline. The IRS found reasonable cause for the late filing and…
PLR 200622007: Late S election accepted from intended incorporation date
A corporation's shareholders intended S corporation treatment from its incorporation date, but the corporation missed the election deadline. The IRS found reasonable cause for the late filing and…
PLR 200622006: Controlled group may revoke alternative research credit election
A corporation had elected the alternative incremental method for calculating the research credit on behalf of its controlled group. It asked to revoke that election for a specified year and later…
PLR 200622005: Reformed charitable trust interests qualify for estate tax deduction
A will created a trust paying one beneficiary 4% of its value each year, with the remainder going to charity at the beneficiary's death. The estate proposed a court reformation that would pay 5%…
PLR 200622004: Replacing trust advisors leaves GST exemption and tax interests intact
A trust created under a will that became irrevocable before September 25, 1985, planned to replace its advisory committee members through the procedure in the will. The IRS found the changes…
PLR 200622003: Foreign insurer gets time to file missing domestic treatment election
A foreign property and casualty insurer intended to elect under IRC § 953(d) to be treated as a domestic corporation. Its parent included a copy of the election with a timely consolidated return,…
PLR 200622002: S election may take effect from incorporation despite missing timely filing
A corporation's vice president said he intended S corporation treatment from its incorporation date, but the IRS had no record of a timely Form 2553. The IRS found reasonable cause for the missing…
CCA 200622001: IRS may share tax information for Alaska's gas project contracts
Alaska planned contracts under its stranded gas development law that would replace certain corporate income tax payments with contract payments calculated using state tax rules. An IRS disclosure…
PLR 200621033: Revised tuition certificate refunds preserve section 529 status
An administrator of a prepaid tuition program had a prior IRS ruling that the program qualified under IRC § 529. Its certificate refund formula used the trust's actual investment return but limited…
PLR 200621032: Gift of oil and gas interest is not itself a jeopardizing investment
A private foundation planned to accept a donated 1% working interest in an oil and gas project and its pipeline, without paying the donor. The interest could bring future operating and capital…
PLR 200621031: Apartment rents preserve exemption but debt creates taxable income
A tax-exempt title-holding company planned to build apartments and lodge space with borrowed funds, then rent the apartments and parking spaces to residents. The IRS ruled that rent from 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.