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 200621030: Building funds count as a foundation qualifying distribution
A private operating foundation was constructing a building for research materials, historic objects, lectures, and staff. Hurricane Katrina had slowed construction, so the foundation sought to set…
PLR 200621029: Court order permits foundation's contingent set-aside
A private foundation's grantmaking was affected by litigation over property left through a donor's trust. A probate court barred trust payments and distributions while the dispute continued, and…
PLR 200621028: University building grant set-aside counts as a qualifying distribution
A foundation planned a grant for construction of a new academic building at a public university. It proposed reserving the money and paying it in installments as construction progressed, with…
PLR 200621027: Veterans group may transfer education programs and retain exemption
A veterans organization planned to transfer its educational programs and related assets to an affiliated educational charity, while keeping its insurance programs for veteran members. The IRS ruled…
PLR 200621026: Education charity keeps exemption after receiving veterans group assets
An educational charity planned to take over a veterans organization's education programs and the assets related to them. The charity would expand its aerospace education work, adopt the veterans…
Determination 200621025: Special needs trust service denied charitable exemption
A nonprofit sought exemption under IRC § 501(c)(3) for providing planning, coordination, and oversight services to families using special needs trusts for named people with disabilities. The IRS…
Determination 200621024: Charitable exemption revoked for private inurement and benefit
The IRS issued a final notice revoking an organization's recognition under IRC § 501(c)(3). It found that the organization had not operated exclusively for exempt purposes, that its earnings…
Determination 200621023: Festival organizer loses charitable exemption
The IRS issued a final letter revoking an organization's recognition under IRC § 501(c)(3). The organization held festivals to promote Mexican American culture, including music, folkloric dance, and…
PLR 200621022: Manufacturer receives a conditional pension funding waiver
The IRS granted a manufacturer's pension plan a waiver of its minimum funding requirement under IRC § 412(d), subject to specified contributions and later funding deadlines. The company reported…
PLR 200621021: Incorrect bank advice leads to an IRA rollover waiver
An IRA owner withdrew money and asked her financial institution how long she had to put it back. A customer service agent incorrectly told her she had 90 days from cashing the check, and she…
PLR 200621020: Surviving spouse may roll a plan distribution through a trust into an IRA
A surviving spouse asked whether a deceased spouse's section 457 plan balance could pass through their joint trust and a subtrust into the survivor's IRA. The plan administrator would pay only the…
TAM 200621019: Synfuel facilities were placed in service before the credit deadline
The IRS considered whether four coal based synthetic fuel facilities were placed in service before July 1, 1998, a deadline relevant to the former IRC § 29 credit. The facilities had permits, had…
CCA 200621018: Bankruptcy stay does not bar intervention in a spouse's Tax Court case
Chief Counsel considered whether a husband's bankruptcy stay prevented him from joining his former wife's Tax Court case about relief from joint tax liability. The wife alone had requested relief…
CCA 200621017: IRS concurs in a railroad employer classification
The Railroad Retirement Board told the IRS that a business had become an employer under two railroad benefit statutes. After reviewing the Board's opinion and submitted information, the IRS agreed…
PLR 200621016: Changing trust advisors does not alter tax treatment
A trust formed under a will that became irrevocable before September 25, 1985 planned to replace its advisory committee members through resignations and appointments allowed by the will. The IRS…
PLR 200621015: Parent and subsidiary receive more time for consolidated return election
A parent company and its newly acquired subsidiary missed the deadline to elect to file a consolidated federal income tax return. The IRS found that the parent reasonably relied on a qualified tax…
PLR 200621014: Corporation gets relief for a late S election
A corporation intended to elect S corporation status from the date it was incorporated but did not file Form 2553 on time. Based on the submitted facts, the IRS found reasonable cause for the delay…
PLR 200621013: Foreign insurer receives more time for domestic corporation election
A foreign insurance company hired an adviser to make an election under IRC § 953(d) to be treated as a domestic corporation for U.S. tax purposes, but the election was not filed by the required…
PLR 200621012: Mutual fund merger qualifies as a stock for assets reorganization
A target mutual fund planned to transfer substantially all its assets and liabilities to an acquiring fund for the acquiring fund's shares, distribute those shares to its investors, and liquidate.…
PLR 200621011: Fund asset transfer qualifies as a reorganization despite planned redemption
A target mutual fund planned to transfer substantially all its assets and liabilities to another fund for shares, distribute those shares to its investors, and liquidate. Before the merger, an…
PLR 200621010: Tribal housing authority qualifies as a tribal instrumentality
A tribe created a housing authority to obtain federal grants and develop low income housing for its members. The tribal council appointed and oversaw the authority's commissioners, could withdraw…
PLR 200621009: S corporation status continues after inadvertent shareholder error
An S corporation issued shares to a nonresident alien, an ineligible shareholder, causing its S election to terminate. The IRS accepted the company's representation that the error was inadvertent…
PLR 200621008: Trust election and income errors receive inadvertent S termination relief
An S corporation's election ended after successor shareholder trusts failed to make qualified subchapter S trust elections. Another shareholder trust also failed to distribute all its income to its…
PLR 200621007: Group receives time to file dual consolidated loss elections
A consolidated corporate group claimed losses from several disregarded entities that were also subject to foreign tax rules, creating dual consolidated losses. Its tax department missed required…
PLR 200621006: Trust advisor changes preserve GST exemption and avoid other tax
A trust created under a will predating September 25, 1985 planned to replace advisory committee members through resignations and appointments allowed by the will. The replacements could include the…
PLR 200621005: Successor trust advisors do not change GST, gift, or income tax treatment
One of three trusts created under a will predating September 25, 1985 planned to replace its advisory committee through sequential resignations and appointments. The replacements would have the same…
PLR 200621004: Dual consolidated loss filings get an extension, with recapture still due
A corporate group missed election agreements and annual certifications required for dual consolidated losses from foreign branches and hybrid entity separate units. The group said turnover and…
PLR 200621003: Divorce related stock transfer receives inadvertent S termination relief
A court ordered transfer of company shares from one former spouse's 401(k) account to the other's IRA caused the company's S corporation election to terminate. The company said it and its…
PLR 200621002: Tribal university qualifies as a tribal instrumentality
A tribe chartered a public university to serve reservation residents and other students. The tribal council appointed and oversaw its leadership, supplied most of its funding, and approved its…
PLR 200621001: Replacing trust advisors preserves GST exemption and avoids other tax
A trust for descendants of one of a decedent's children planned to replace its advisory committee through resignations and appointments authorized by the decedent's will. The decedent died before…
PLR 200620036: Aquaculture school receives an advance ruling on public charity status
A private operating foundation that teaches marine aquaculture to local students sought to end its private foundation status by qualifying as an educational organization. It had regular instructors,…
PLR 200620035: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620034: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620033: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620032: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620031: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620030: Estate partnership redemption falls within self dealing exception
A private foundation expected eventually to receive an interest tied to a family limited partnership after its founder's death. A redemption agreement would cause the partnership to buy back units…
PLR 200620029: Bank trustee's contingent sale payment is not foundation self dealing
A bank that served as trustee of a private foundation sold an investment management division to another bank. The sale price depended partly on management fees from assets that stayed invested,…
PLR 200620028: IRA rollover deadline waived after mistaken distribution advice
A surviving spouse intended to move her late husband's IRA through a trust subtrust into an IRA in her own name without an immediate taxable distribution. Despite instructions from her lawyer and…
PLR 200620027: IRA rollover deadline waived after custodian placed funds in a non-IRA account
A bank required an IRA owner to move her investments to its brokerage division. The receiving financial institution mistakenly put the funds in a non-IRA account. She did not discover the error…
PLR 200620026: Trust qualifies for life expectancy distributions from inherited IRA and plan
A deceased IRA owner and retirement plan participant named his trust as beneficiary. The trust allocated both retirement interests to a subtrust for his two daughters, and its amended terms required…
PLR 200620025: IRA share may move to a beneficiary's special needs trust without a taxable transfer
An IRA owner left equal shares to his four sons. One disabled son risked losing eligibility for public benefits if he directly owned his share, so his guardian proposed moving it to an IRA…
PLR 200620024: Ten-year extension granted for pension plan funding shortfalls
A multiemployer pension plan asked for more time to amortize unfunded liabilities after heavy investment losses and the bankruptcy of a major contributing employer. The IRS granted a 10-year…
CCA 200620023: Research credit base includes receipts from foreign subsidiaries
A domestic corporation sold products and licensed intangibles to foreign subsidiaries. After including those receipts in its research credit calculation, it sought refunds by excluding them from…
CCA 200620022: Foreign tax credits disallowed for a brief, hedged share transaction
A U.S. financial services company purported to buy entities holding shares of a foreign corporation, hedge its exposure with options, and return the shares to the seller about two months later. It…
PLR 200620021: Replacing trust advisors preserves tax treatment
A trust created under a will predating the generation-skipping transfer tax proposed to replace all three members of its advisory committee through resignations and appointments allowed by the will.…
PLR 200620020: Estate gets more time to elect family business deduction
An estate did not elect the qualified family-owned business deduction on its timely filed estate tax return because its original stock valuation did not meet the threshold for the election. A…
PLR 200620019: Taxpayer may revise investment income election for dividends
A taxpayer used tax software to elect to treat all qualified dividend income as investment income for the investment interest deduction. The software did not calculate or explain the optimal amount…
PLR 200620018: Taxpayer may revise investment income election for dividends
A taxpayer used tax software to elect to treat all qualified dividend income as investment income for the investment interest deduction. The software did not calculate or explain the optimal amount…
PLR 200620017: Treaty business activity tests for interest from U.S. affiliates
A Country A financing company received interest from affiliated U.S. companies and asked how the active business provision of a U.S. income tax treaty applies. The IRS ruled that a Country B parent…
PLR 200620016: Foreign distributor's settlement principal is foreign-source income
A nonresident alien distributor settled a claim that a U.S. supplier wrongfully ended a contract for sporting goods sold abroad. The distributor's attorney asked whether the settlement could be paid…
PLR 200620015: Company receives more time to elect DISC status
A company intended to operate as a domestic international sales corporation (DISC), but it missed the election and shareholder consent filings. Its treasurer expected an outside law firm to handle…
PLR 200620014: Six funds' late returns count as timely for a dividend election
Six regulated investment companies filed returns containing an IRC § 855(a) dividend election six days after the due date. Their normal signing and filing process changed shortly before the…
PLR 200620013: Ineligible shareholder does not defeat retroactive S corporation relief
A corporation elected S corporation status when some of its stock was held by an ineligible shareholder. The shareholder later transferred the stock to eligible owners, and the company's advisors…
PLR 200620012: Adding a co-trustee preserves two trusts' GST exemption
Beneficiaries of two trusts that became irrevocable before September 25, 1985, proposed asking a court to add a grandson as co-trustee for investment decisions. The IRS ruled that this was an…
PLR 200620011: Adding a co-trustee preserves two trusts' GST exemption
Beneficiaries of two trusts that became irrevocable before September 25, 1985, proposed asking a court to add a grandson as co-trustee for investment decisions. The IRS ruled that this was an…
PLR 200620010: Foreign entity gets more time to elect partnership treatment
A foreign entity with two owners who had limited liability intended to be treated as a partnership for U.S. federal tax purposes when it became active. It missed the deadline for the entity…
PLR 200620009: Foreign entity gets time to elect disregarded status
A foreign eligible entity missed the filing deadline to elect treatment as disregarded from its owner for U.S. federal tax purposes. The IRS found that it satisfied the requirements for an extension…
PLR 200620008: Foreign entity gets time to elect disregarded status
A foreign eligible entity missed the filing deadline to elect treatment as disregarded from its owner for U.S. federal tax purposes. The IRS found that it satisfied the requirements for an extension…
PLR 200620007: Late S corporation election allowed for original effective date
A corporation intended to elect S corporation status when it was incorporated but did not file Form 2553 on time. The IRS found reasonable cause for the missed deadline under IRC § 1362(b)(5). It…
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.