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 200609009: Foreign entity receives time to elect disregarded status
A foreign eligible entity intended to elect disregarded entity classification for U.S. tax purposes but inadvertently missed the Form 8832 filing deadline. The IRS accepted the submitted facts and…
PLR 200609008: Foreign entity receives time to elect disregarded status
A foreign eligible entity intended to elect disregarded entity classification for U.S. tax purposes but inadvertently missed the Form 8832 filing deadline. The IRS accepted the submitted facts and…
PLR 200609007: Foreign entity receives time to elect disregarded status
A foreign eligible entity intended to elect disregarded entity classification for U.S. tax purposes but inadvertently missed the Form 8832 filing deadline. The IRS accepted the submitted facts and…
PLR 200609006: Foreign entity receives time to elect disregarded status
A foreign eligible entity intended to elect disregarded entity classification for U.S. tax purposes but inadvertently missed the Form 8832 filing deadline. The IRS accepted the submitted facts and…
PLR 200609005: Foreign entity receives time to elect disregarded status
A foreign eligible entity intended to elect disregarded entity classification for U.S. tax purposes but inadvertently missed the Form 8832 filing deadline. The IRS accepted the submitted facts and…
PLR 200609004: Utility group receives tax rulings for SEC ordered divestiture
A publicly traded utility holding company faced a Securities and Exchange Commission order to dispose of nonutility investments it could not retain. It proposed a series of transfers among…
PLR 200609003: Converting old income trusts to unitrusts preserves tax treatment
Trustees of two irrevocable trusts created before September 25, 1985 planned to ask a state court to replace income based beneficiary payments with unitrust payments based on a court set percentage…
PLR 200609002: Wind project partnership qualifies for electricity production credits
A planned partnership would acquire a company developing a wind turbine project and sell the project's electricity to an unrelated utility. The IRS ruled that each turbine would be placed in service…
PLR 200609001: Wind project partnership qualifies for electricity production credits
A planned partnership would acquire a company developing a wind turbine project and sell the project's electricity to an unrelated utility. The IRS ruled that each turbine would be placed in service…
CCA 200608038: IRS said California domestic partners reported own 2005 earnings
Chief Counsel addressed how a California registered domestic partner should report personal service income for tax year 2005 after the state's Domestic Partner Rights and Responsibilities Act took…
PLR 200608037: S corporation spin off receives reorganization treatment
An S corporation with two active businesses proposed transferring one business to a new corporation and distributing all of the new corporation's stock pro rata to its four shareholders. The new…
PLR 200608036: IRS waives IRA rollover deadline after annuity misunderstanding
A taxpayer withdrew funds from an IRA funded by a certificate of deposit, intending to roll them into another IRA. After meeting with her financial advisor, she used funds from a checking account to…
PLR 200608035: Home purchase IRA redeposit qualifies for 120-day period
A first-time home buyer withdrew money from his IRA to buy a condominium. He canceled the purchase after delays involving the mortgage provider and returned the money to the IRA about 79 days after…
PLR 200608034: IRS waives IRA rollover deadline after unauthorized liquidation
A widow inherited her spouse's IRA. Another person liquidated it while purporting to act under a power of attorney, but the widow's representative said that person lacked authority under state law.…
PLR 200608033: IRS gives couple more time for IRA rollovers after firm error
A married couple instructed an investment firm in writing to move distributions from their separate IRAs into other IRAs. The firm put the proceeds in accounts that were not IRAs, and the couple…
PLR 200608032: Trust beneficiaries may use eldest child's life expectancy for inherited IRA distributions
A decedent left an IRA to a trust benefiting six children and three charities. The charities received their shares before the beneficiary determination date, and the remaining trust provisions…
PLR 200608031: IRA rollover deadline waived after bank opens wrong account
A retiree withdrew money from an IRA to move it into an IRA certificate of deposit at another financial institution. A misunderstanding with its representative led to the money being placed in an…
PLR 200608030: Couple gets more time to undo ineligible Roth IRA conversions
A married couple converted funds from traditional IRAs to Roth IRAs, unaware that their combined income exceeded the $100,000 limit then applicable to conversions. They also missed the deadline to…
PLR 200608029: Widow may complete deceased spouse's plan rollover and then roll into her IRA
A plan participant directed that his qualified retirement plan distribution be sent to his IRA, but the checks were mailed on the date of his death. The IRA custodian refused them, and his surviving…
PLR 200608028: IRA rollover deadline waived after investment lands in joint account
A taxpayer asked his IRA custodian to transfer funds to another IRA to hold an investment in a company. Instead, the funds went to an account held jointly with his spouse, which could not serve as…
PLR 200608027: Grieving parent gets more time to roll over unused IRA funds
A taxpayer withdrew his IRA balance intending to move it to another IRA, but his daughter died before he completed the rollover. He tried to deposit the funds shortly after the 60-day deadline, and…
PLR 200608026: Mistaken online transfer from IRA qualifies for deadline waiver
A taxpayer intended to move money between investments within his IRA. In an online transaction, he accidentally moved it to a non-IRA money market account at the same company. He discovered the…
PLR 200608025: Caregiver receives IRA rollover deadline waiver
A taxpayer withdrew her IRA balance intending to move it to another IRA. While caring full time for her bedridden mother, who was also hospitalized, she mistakenly deposited the money in a non-IRA…
PLR 200608024: Minimum funding waiver denied because hardship was not temporary
A nonprofit company requested a waiver of the minimum funding standard for its plan year ending December 31, 2004. It cited declining revenue and losses tied to government reimbursement and local…
IRS notice 200608023: Item pulled for administrative error
The official IRS PDF for number 200608023 says only that the item was pulled for an administrative error. The released page does not identify the underlying taxpayer or tax question. It provides no…
CCA 200608022: Serving a corporate summons through a registered agent
Chief Counsel considered whether the IRS could serve an administrative summons directed to a corporation on its registered agent or a state official authorized to receive process. It found a…
PLR 200608021: Estate receives extension to allocate GST exemption as trust directed
An estate filed its Form 706 late after its accountant said a late return would cause no adverse consequences because no estate tax was due. The accountant did not warn that missing the filing…
PLR 200608020: Corporation receives relief for a late S corporation election
A corporation intended to elect S corporation status from the date it was incorporated but did not file its election on time. The IRS found reasonable cause for the missed deadline under §…
PLR 200608019: Estate receives 60 days to elect the QTIP marital deduction
An estate filed its federal estate tax return without electing the qualified terminable interest property (QTIP) marital deduction for part of a credit shelter trust. The return mistakenly reported…
PLR 200608018: Foreign subsidiary restructuring qualifies as an F reorganization
A corporate group proposed moving a foreign subsidiary's operations under a newly formed foreign corporation as part of a broader financing and cash distribution plan. The IRS ruled that the…
PLR 200608017: Foreign entity receives time to elect partnership classification
A foreign entity changed from a corporation to a limited liability partnership under its home country's law. Its owners intended to elect partnership treatment for U.S. tax purposes from that date,…
PLR 200608016: IRS rules on corporate separation and related spin-offs
A publicly traded corporate group proposed a complex separation of businesses through subsidiary conversions, liquidations, internal spin-offs, and a distribution of stock in a new controlled…
PLR 200608015: Foreign entity receives extension for partnership election
A foreign entity had two members, both with limited liability. Its members wanted U.S. partnership tax treatment from a specified date, but the entity did not file Form 8832 on time. Under the…
PLR 200608014: Parent receives more time to request consolidated return waiver
A parent's restructuring inadvertently removed a subsidiary from its consolidated tax group; the subsidiary later rejoined. Section 1504(a)(3)(A) normally delays a returning subsidiary's inclusion…
PLR 200608013: Form 3115 treated as timely after security delay
A parent corporation prepared its consolidated return with a subsidiary's Form 3115 for an accounting method change, but its courier could not mail the return on the due date. The IRS letter says an…
PLR 200608012: Groundwater lease preserves farm valuation except on extraction land
An estate had valued farmland based on its farming use under § 2032A. Trusts holding the land proposed leasing groundwater rights to a water authority and granting an easement to remove the water,…
PLR 200608011: Gift to social club qualifies as one present-interest gift
A member planned to give money to a nonprofit social club for capital improvements and repayment of related debt. The member sought gift tax annual exclusions as though the gifts were made to each…
PLR 200608010: Late trust elections do not end corporation's S status
Four trusts received shares of an S corporation, but their income beneficiaries did not timely make qualified subchapter S trust (QSST) elections. That lapse terminated the corporation's S election…
PLR 200608009: Shared transmission capacity does not make bonds private activity bonds
A governmental agency financed electric transmission facilities with bonds and proposed operating those facilities jointly with an investor-owned utility's transmission system. The parties expected…
PLR 200608008: Parents receive time to allocate GST exemptions to trust
A husband and wife made gifts to a trust for their daughter and her descendants over several years without allocating their generation skipping transfer (GST) exemptions. After their daughter died,…
PLR 200608007: Changing trust royalty allocations preserves GST exemption
An older trust had allocated most oil and gas royalty receipts to current income under the state law in effect when its will was signed. Later state law allowed its trustee to allocate those…
PLR 200608006: Foreign entity receives time to elect disregarded status
A foreign entity represented that it was eligible to elect disregarded entity treatment for U.S. tax purposes but had inadvertently failed to file Form 8832 on time. The IRS found that it met the…
PLR 200608005: Late S election receives reasonable cause relief
A corporation's shareholders intended S corporation treatment from a specified date, but the corporation missed the election deadline. The IRS found reasonable cause for the late filing under §…
PLR 200608004: Grantors receive extension for GST exemption allocations
Two grantors made gifts to a trust for their children and descendants over multiple years, but their advisers failed to allocate their generation skipping transfer (GST) exemptions. The IRS found…
PLR 200608003: Proposed trust terms preserve pooled income fund eligibility
A tax exempt medical organization created a pooled income fund to finance new buildings that the fund would lease to the organization. The IRS ruled that four proposed trust terms would not…
PLR 200608002: Proposed trust terms preserve pooled income fund eligibility
A tax exempt medical organization created a pooled income fund to raise capital to buy and renovate buildings that the fund would lease to the organization. The IRS ruled that four proposed trust…
PLR 200608001: Court ordered trust changes preserve GST tax exemption
A trust established under a will became irrevocable before September 25, 1985, making it eligible for an exemption from generation skipping transfer (GST) tax. Its terms required an outright…
PLR 200607031: Inherited IRA trust may use oldest beneficiary's life expectancy
An IRA owner died before his required distribution date and had named a subtrust as the IRA's beneficiary. The trustee amended the trust to require IRA withdrawals to be paid out to its…
PLR 200607030: IRA rollover deadline waived after bank opened the wrong account
An IRA owner directed a transfer to a new institution to obtain a better interest rate. The new institution assured him that it had opened an IRA certificate of deposit, but it put the money in a…
PLR 200607029: Hospital pension funding waiver requests denied
A hospital asked the IRS to waive minimum funding requirements for its pension plan for the 2002 and 2003 plan years. The hospital reported reduced reimbursement revenue, recurring losses, cash flow…
PLR 200607028: Foundation may pay founder owned bank for investment services
A private foundation proposed to hire a bank owned indirectly by its founder to manage its investments. The IRS treated the bank as a disqualified person with respect to the foundation, which made…
PLR 200607027: Foundation may transfer assets to successor after state dissolution
A private foundation lost its state corporate status through an administrative termination but continued its charitable operations and federal filings. It formed a successor with the same officers…
PLR 200607026: Foundation scholarship procedures receive advance approval
A private foundation proposed scholarships for high school seniors and full time college or vocational students across the United States. A publicly supported charity would handle applications,…
PLR 200607025: County affiliated hospital need not file its own Form 990
A tax exempt hospital asked whether it still needed to file its own annual Form 990 after combining operations with another hospital. A new nonprofit managed both hospitals' assets and reported the…
PLR 200607024: Housing authority affiliate need not file Form 990
A tax exempt organization created by a city housing authority provided low income housing. The authority appointed two of its five directors, and those two had to agree unanimously on the other…
PLR 200607023: Foundation may settle disputed bequest without excise taxes
A private foundation received rental properties from a donor's trust, but the donor's relatives challenged the estate plan and a court froze the foundation's assets. The parties negotiated a court…
PLR 200607022: Council on aging need not file Form 990
A council on aging provided transportation, meals, prescription assistance, and other services to older residents. State law authorized and regulated the council, and state agencies supervised its…
TAM 200607021: Manufacturer removed inventory costs through the wrong formula entry
A manufacturer received IRS consent to stop including several specified costs in inventory and deduct them currently. It had included those costs in inventory before section 263A took effect, making…
TAM 200607020: Stock conversion ends insurer's special Blue Cross tax benefits
A Blue Cross or Blue Shield insurer converted from a nonprofit mutual company to a publicly traded, for profit stock company. The IRS advised that issuing stock changed the insurer's ownership and…
CCA 200607019: Refund claims for fiscal year deposits have a six year limit
Partnerships and S corporations that elect certain fiscal years must maintain required payments with the IRS under section 7519. Chief Counsel concluded that these payments function as refundable…
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.