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 200551026: Broker's account error led to IRA rollover deadline waiver
A taxpayer asked a broker to withdraw money from a personal account. The broker instead took it from the taxpayer's IRA, and the taxpayer learned of the mistake only after receiving a Form 1099,…
PLR 200551025: Foundation's investment alongside founder's group avoided self-dealing
A private foundation proposed to invest in a fund alongside its founder and related parties, who were disqualified persons under the foundation rules. The IRS ruled that the foundation's…
PLR 200551024: Foundation grant to foreign charity received three favorable rulings
A domestic private foundation proposed to grant more than 25% of its assets to a foreign charitable foundation controlled by the same five directors. The foreign foundation did not have a U.S.…
PLR 200551023: Regional LLC preserved charity's exemption and related income treatment
A publicly supported charity proposed to form regional, single-member LLCs to expand its public policy research and community work. A local charity would appoint most directors of the first LLC,…
CCA 200551022: Railroad business ceased to be an employer for tax purposes
The Railroad Retirement Board told the IRS that a business had ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed that…
CCA 200551021: Railroad business no longer had employer status
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. Chief Counsel reviewed the…
PLR 200551020: Trustee changes preserved ten trusts' generation-skipping tax exemption
A grantor had created ten irrevocable trusts for children before September 25, 1985. A court approved changes to their trustee provisions, contingent on a favorable IRS ruling. The changes would…
PLR 200551019: Earlier bond ruling amended to remove a fixed power capacity figure
A company asked the IRS to change a 1983 private letter ruling about bonds financing a public issuer's interest in an energy project. The earlier ruling contained a formula limiting the energy the…
PLR 200551018: New corporation could amortize purchased goodwill over 15 years
An S corporation planned to sell its business assets to a new corporation with an overlapping owner. The buyer would allocate part of the price to goodwill and asked whether it could amortize that…
PLR 200551017: Partnership could deliver Schedule K-1s electronically with consent
A partnership wanted to stop mailing paper Schedule K-1s to partners who agreed to receive them through a secure website. The IRS ruled that electronic delivery would satisfy § 6031(b) if the…
PLR 200551016: Exempt Dutch dividends counted in treaty gross income test
A Netherlands holding company expected dividends from its U.S. subsidiary and sought benefits under the U.S.-Netherlands income tax treaty. It asked whether those dividends counted as gross income…
PLR 200551015: Shareholder approved amendment restarted stock option plan's ten year clock
A corporation increased the maximum number of shares available under its incentive stock option plan, and its shareholders approved the amendment. It later changed the period for issuing options…
PLR 200551014: Housing project received extra time to make set-aside election
A taxpayer intended to choose the 40/60 minimum set-aside for a low-income housing project but failed to make the election properly for the relevant tax year. The IRS granted an extension after…
PLR 200551013: Terminal illness required a special factor for life estate gifts
A taxpayer gave up life estate interests in twenty parcels of real property, transferring those interests to the remainder owners. At the time, the taxpayer had a terminal illness with at least a…
PLR 200551012: Consolidated group received more time to waive loss carryback
A consolidated corporate group intended to give up the carryback period for a consolidated net operating loss, but its timely return lacked a valid election statement. The IRS found that the…
PLR 200551011: Group got extra time to waive a prior year's loss carryback
A consolidated corporate group filed its return on time but did not include a valid election to waive the carryback period for that year's consolidated net operating loss. The IRS found that the…
PLR 200551010: Consolidated group granted late loss carryback waiver election
A consolidated group meant to waive the carryback period for a consolidated net operating loss, but its timely return did not include a valid election. The IRS found that the group had reasonably…
PLR 200551009: Estate received time to allocate missed generation-skipping exemption
A taxpayer made gifts to a family trust, but tax professionals did not allocate generation-skipping transfer (GST) exemption on the gift tax returns. The couple's earlier gift splitting election had…
PLR 200551008: Replacement injury payments excluded, class counsel fees not income
A person injured in an automobile accident had a structured settlement, but payments stopped after assets meant to fund it were sold. A later class action produced a settlement intended in part to…
PLR 200551007: Six branches added to late certification relief
A taxpayer had already received extra time to file statements concerning dual consolidated losses. While preparing those filings, it discovered that the earlier ruling's schedule omitted…
PLR 200551006: Group received time to file foreign loss elections
A U.S. corporate group had claimed losses of a foreign entity and its three branches but had not filed the related elections and agreements. Its international tax manager did not realize the filings…
PLR 200551005: Mistaken direct skip classification led to late GST allocation relief
A taxpayer gave property to four trusts benefiting children, grandchildren, and later descendants. An accountant mistakenly reported the gifts as direct skips and assumed generation-skipping…
PLR 200551004: S corporation election treated as timely after missing filing record
A company and its shareholder said they had intended S corporation status from the company's start. The company represented that it filed Form 2553 on time, but the IRS had no record of the filing;…
PLR 200551003: Late S corporation election accepted for first tax year
A company's shareholders intended it to be an S corporation from its start, but Form 2553 was not filed on time. The company and shareholders had filed returns consistent with S corporation…
PLR 200551002: LNG and crude oil shipping income qualified under partnership rule
A publicly traded limited partnership planned to operate ships carrying liquefied natural gas and crude oil under charter agreements. It would supply the crews, choose routes, maintain the ships,…
PLR 200551001: Distribution to successor trust preserved stated tax treatment
Trustees proposed to distribute assets from a beneficiary's trust, created under an irrevocable trust established before September 25, 1985, into a new trust for that beneficiary and his children.…
Other 200550045: Insurer's tax exemption revoked effective 2001
The IRS issued a final adverse determination revoking an organization's exemption under § 501(c)(15), effective January 1, 2001. The letter says the organization agreed to the revocation, which was…
Other 200550044: Insurer exemption revoked after failing insurance company test
The IRS issued a final adverse determination revoking an organization's exemption under § 501(c)(15). The letter says the organization was not operated as an insurance company during the years…
PLR 200550043: Retiree medical account contributions must reflect funding after the account began
A company asked how much it could contribute to a retiree medical account within its pension plan while keeping medical benefits subordinate to retirement benefits under § 401(h). The IRS accepted…
PLR 200550042: Government pension members may buy qualifying service credit with direct plan transfers
A state retirement system asked whether members could buy credit for certain past employment and extra school year months under its pension plans. The IRS ruled that the credit qualifies as…
PLR 200550041: Postal forwarding failure justified a retirement rollover deadline waiver
A former employee missed the 60 day deadline to roll a distribution from a terminated retirement plan into an IRA. The plan mailed the distribution check and tax form to his former address, and the…
PLR 200550040: Deposit into a regular account justified an IRA rollover deadline waiver
An IRA owner asked the IRS to waive the 60 day rollover deadline after money intended for a new IRA was deposited in a regular bank account. He said he instructed the receiving bank to put the money…
PLR 200550039: A cash balance plan lump sum does not disrupt the remaining annuity payments
An employer asked how an optional lump sum from its cash balance pension plan would affect the monthly annuity paid from the remaining balance. The IRS ruled that a lump sum much larger than the…
PLR 200550038: Bank delays justified a waiver for a retirement plan loan rollover
After leaving an employer, an individual received notice that an outstanding plan loan had been foreclosed and that he could roll over the resulting amount to an IRA. He tried to arrange the…
TAM 200550037: Modified motorhome chassis remained taxable truck chassis
A seller asked whether two chassis used for motorhomes were subject to the federal excise tax on the first retail sale of truck chassis under § 4051. The parties agreed that the living quarters…
PLR 200550036: Taxpayer receives more time to file a dual consolidated loss agreement
After a merger, a corporation needed to file an election and agreement concerning a subsidiary's earlier dual consolidated losses. Its tax adviser explained a related closing agreement requirement…
PLR 200550035: Corporation gets 45 days to correct dual consolidated loss filings
A corporate group claimed dual consolidated losses connected to two foreign entities, but some required elections and annual certifications were missing or signed by someone who lacked authority to…
PLR 200550034: Partnership gets 30 days to attach a missing accounting method form
A partnership changed how it deducted prepaid expenses and applied the recurring item exception on its timely filed return. It also sent a copy of Form 3115 to the IRS National Office, but failed to…
PLR 200550033: Partnership gets 30 days to attach a missing accounting method form
A partnership changed how it deducted prepaid expenses and applied the recurring item exception on its timely filed return. It also sent a copy of Form 3115 to the IRS National Office, but failed to…
PLR 200550032: Material foreign tax law change permits revocation of safe harbor election
A corporate group had elected a safe harbor method for determining how much of certain foreign levies could count toward its foreign tax credit. The foreign country later changed its tax law,…
PLR 200550031: Possible partnership shareholders receive inadvertent S election relief
A corporation's shares were held by partnerships when it elected S corporation status. The corporation intended the partnerships to hold the shares as nominees for eligible shareholders, but the…
PLR 200550030: LLC gets more time to elect corporate tax classification
A limited liability company intended to be taxed as a corporation from the date it was formed, but did not file Form 8832 on time. It asked the IRS for relief from the election deadline. The IRS…
PLR 200550029: Late GST exemption allocations may use original trust transfer values
A taxpayer funded two irrevocable trusts for his children but did not file a gift tax return or allocate his generation skipping transfer tax exemption to the transfers. He said his accountant had…
PLR 200550028: Late GST exemption allocation may use original trust transfer value
A taxpayer funded an irrevocable trust for her child but did not file a gift tax return or allocate her generation skipping transfer tax exemption to the transfer. She said her accountant had not…
PLR 200550027: Late GST exemption allocations may use original values for two trusts
A taxpayer funded two irrevocable trusts for her children but did not file a gift tax return or allocate her generation skipping transfer tax exemption to the transfers. She said her accountant had…
PLR 200550026: Replacing fuel plant parts preserves its credit eligibility
A partnership owned a synthetic fuel facility and replaced worn briquetter rolls and hydraulic motors. The IRS ruled that replacing the parts would not give the facility a new placed in service date…
PLR 200550025: Domestic company may use foreign currency selection principles
A domestic company planning to qualify as a real estate investment trust expected most of its activities, revenues, expenses, and records to use a foreign currency. It asked to select its functional…
PLR 200550024: Corporation receives relief for a late S election
A corporation's sole shareholder wanted S corporation treatment from the date the company was incorporated, but its election was filed late. The IRS found reasonable cause for the missed deadline…
PLR 200550023: Partnership gets more time to elect corporate classification
An S corporation converted under state law into a limited partnership. The partnership intended to elect corporate tax classification effective on the conversion date but missed the Form 8832…
PLR 200550022: Late S corporation election may take effect at incorporation
A corporation's sole shareholder intended it to be an S corporation from its incorporation date, but no Form 2553 was filed on time. The IRS found reasonable cause for the missed deadline. It ruled…
PLR 200550021: Business sale proceeds may fund a partial liquidation
A corporation sold substantially all assets of a discontinued business and planned to distribute much of the net proceeds to its shareholders while continuing two other businesses. The IRS ruled…
PLR 200550020: Late S election may be effective from incorporation
A corporation's shareholders intended it to be an S corporation from incorporation, but no Form 2553 was filed on time. The IRS found reasonable cause for the late election under section 1362(b)(5).…
PLR 200550019: Corporation receives relief for late S election
A corporation's sole shareholder intended it to be an S corporation from incorporation, but no Form 2553 was filed on time. The IRS found reasonable cause for the missed deadline. It ruled that an…
PLR 200550018: Corporation receives relief for late S election
A corporation wanted S corporation treatment from a specified date but filed its election late. The IRS found reasonable cause for the missed deadline and ruled that the corporation would be…
PLR 200550017: Related entities may use foreign currency selection rules
A U.S. limited liability company planning to elect real estate investment trust status and four related entities expected to conduct most transactions in a foreign currency and keep their records in…
PLR 200550016: Late trust elections receive inadvertent S termination relief
A shareholder transferred S corporation shares to two trusts for minor grandchildren, but their legal guardian did not make timely qualified subchapter S trust elections. The IRS found that this…
PLR 200550015: Trust created three separate trusts at the settlor's death
A settlor's trust provided equal shares for the grandchildren living at her death. The trustees kept the assets in one fund, and two more grandchildren joined the family afterward. A state court…
PLR 200550014: Married taxpayers get more time to group rental properties
A married couple filed a joint return without the statement needed to elect to treat all their rental real estate interests as one activity. The IRS granted them 60 days to make the election…
PLR 200550013: Late S election may take effect on requested date
A corporation's sole shareholder intended S corporation treatment from a specified date, but no Form 2553 was filed on time. The IRS found reasonable cause for the missed deadline. It ruled that an…
PLR 200550012: Late S election may take effect on requested date
A corporation's sole shareholder intended S corporation treatment from a specified date, but no Form 2553 was filed on time. The IRS found reasonable cause for the missed deadline. It ruled that an…
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.