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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 200545023: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545022: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545021: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545020: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545019: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545018: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545017: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545016: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545015: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545014: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545013: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545012: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545011: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545010: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545009: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545008: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545007: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545006: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545005: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545004: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545003: Forty-one partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to file Forms 8716 electing a November 30 tax year under section 444. The IRS found that the partnerships acted reasonably…
PLR 200545002: Utility receives revised schedule for nuclear decommissioning fund
A utility requested a revised schedule of deductible payments to its qualified nuclear decommissioning fund after its regulator increased the plant's decommissioning cost collections. The IRS found…
PLR 200545001: Regional business separation qualifies as a D reorganization
A corporation transferred part of its regional business and cash to a newly formed corporation, then distributed the new corporation's stock to its parent. The IRS ruled that the contribution and…
PLR 200544032: Surviving spouse may roll over IRA proceeds received through an estate
An IRA owner died without naming a beneficiary, so the IRA proceeds were payable to his estate. His surviving spouse was both the estate's executor and its sole residuary beneficiary. She proposed…
PLR 200544031: IRA rollover deadline waived after funds went into savings account
A 94 year old IRA owner intended to move a distribution into a new IRA at a bank near a new home. The owner believed the rollover had been completed, but the bank placed the money in a passbook…
PLR 200544030: Surviving spouse receives waiver for late IRA annuity rollover
After her husband's death, a surviving spouse cashed out an annuity without knowing it was an IRA. The custodian had not identified it as an IRA or explained the rollover deadline, and she deposited…
PLR 200544029: Couple receives more time to reverse ineligible Roth IRA conversions
A married couple converted traditional IRAs to Roth IRAs while expecting their income to fall below the then applicable $100,000 conversion limit. They later discovered previously unreported foreign…
PLR 200544028: Hospital receives conditional pension funding and excise tax waivers
A nonprofit teaching hospital sought relief after pension investment losses, a nursing strike, rising insurance costs, and management problems strained its finances. The IRS granted waivers of the…
PLR 200544027: IRA owner denied late rollover relief for real estate purchase
An IRA owner directed his account custodian to send funds to an escrow company for a real estate purchase. He titled his interest in the property in his own name as trustee for the IRA, believing…
PLR 200544026: IRA owner gets more time for rollover after bank advice
An IRA owner wanted to move funds into an IRA that could hold real estate notes. Bank employees advised her to first move the money into an ordinary checking account, then write a check to buy a…
PLR 200544025: IRA withdrawal for divorce payment fails rollover deadline
A woman withdrew money from her IRA to make a divorce settlement payment to her former husband while she waited to sell their former home. The home sale proceeds arrived after the 60 day IRA…
PLR 200544024: Government pension contributions treated as employer payments
A political subdivision adopted a resolution to pay mandatory employee contributions to its defined benefit pension plan. The contributions could be funded by salary reductions or offsets against…
PLR 200544023: Recalculated IRA payments qualify for early distribution exception
A 50 year old IRA owner proposed annual payments calculated using an annuity factor based on her age, the account balance, a mortality table, and an interest rate capped at 120 percent of the…
PLR 200544022: Hurricane does not excuse IRA home purchase rollover delay
An IRA owner used a withdrawal to buy a home, planning to replace the funds with proceeds from a home equity loan. A hurricane damaged the home and delayed the loan until after both the normal…
PLR 200544021: School site parcel sales excluded from unrelated business income
A tax exempt organization acquired land to help a governmental school district build a high school. Construction left several surplus parcels that the organization planned to sell in two…
Determination 200544020: Home care registry denied social welfare exemption
An organization applied for section 501(c)(4) exemption for a registry that matched residents of five related facilities with home care workers. It charged fees for arranging services. The IRS…
Determination 200544019: Debt management seller denied charitable exemption
A company selling debt management plans applied for section 501(c)(3) exemption while still incorporated as a for profit stock corporation. The IRS found that it failed the organizational test and…
PLR 200544018: Insurance investment portfolios qualify as partnerships without public trading
A life insurer used investment portfolios to support its variable life insurance and annuity contracts. It planned to sell portfolio units to segregated accounts of other domestic insurers and asked…
PLR 200544017: Changing a trust's governing law preserves its tax treatment
The trustees of an irrevocable family trust wanted to change its governing state law to simplify administration alongside other trusts in an investment partnership. The new state's law would let…
PLR 200544016: Mutual funds may revoke distribution calculation elections
Six regulated investment companies had elected to use their taxable years, instead of a period ending October 31, to calculate capital gain distributions required under section 4982. They asked to…
PLR 200544015: REIT receives extra time to elect subsidiary tax treatment
A real estate investment trust acquired another trust and its taxable REIT subsidiary in a merger, but did not file a new election for the acquired subsidiary. Its advisers initially concluded that…
PLR 200544014: Family corporation's division receives tax-free reorganization rulings
A family corporation planned to transfer part of its business to a new subsidiary, then give the subsidiary's shares to three family shareholders in exchange for their existing shares. The…
PLR 200544013: Partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to elect a November 30 tax year on Form 8716. They asked the IRS to treat late elections as timely. The IRS found that an…
PLR 200544012: Partnerships receive more time to elect a November tax year
Forty-one related partnerships in a tiered structure missed the deadline to elect a November 30 tax year on Form 8716. They asked the IRS to treat late elections as timely. The IRS found that an…
IRS notice 200544011: Determination pulled for revisions
The official IRS PDF for number 200544011 says the item was pulled and that new revisions were made. It contains no facts, legal analysis, or substantive ruling. The notice gives no issue date or…
IRS notice 200544010: Determination pulled for revisions
The official IRS PDF for number 200544010 says the item was pulled and that new revisions were made. It contains no facts, legal analysis, or substantive ruling. The notice gives no issue date or…
IRS notice 200544009: Determination pulled for revisions
The official IRS PDF for number 200544009 says the item was pulled and that new revisions were made. It contains no facts, legal analysis, or substantive ruling. The notice gives no issue date or…
IRS notice 200544008: Determination pulled for revisions
The official IRS PDF for number 200544008 says the item was pulled and that new revisions were made. It contains no facts, legal analysis, or substantive ruling. The notice gives no issue date or…
PLR 200544007: Retirement trust mergers preserve tax basis and holding periods
A corporate group maintained several retirement plans whose assets were held in six collective trusts. It proposed merging four of the trusts into the other two to reduce administrative costs. Each…
PLR 200544006: Mutual insurer's conversion and acquisition receive tax-free treatment
A mutual life insurer planned to convert to a stock company and become part of another mutual holding company. Its policyholders would exchange their membership interests for interests in the new…
PLR 200544005: Manufacturer gets more time to file inventory cost election
A manufacturer had prepared a statement electing a historic absorption ratio for allocating production costs to inventory, but mistakenly left it in its tax return work papers. Its returns had…
IRS notice 200544004: Determination pulled for revisions
The official IRS PDF for number 200544004 says the item was pulled and that new revisions were made. It contains no facts, legal analysis, or substantive ruling. The notice gives no issue date or…
PLR 200544003: Utility receives revised nuclear decommissioning fund schedule
An electric utility sought a revised schedule governing deductible payments to a nuclear plant decommissioning fund. Two utility commissions had reduced the decommissioning costs assigned to that…
PLR 200544002: Utility receives revised nuclear decommissioning fund schedule
An electric utility sought a revised schedule governing deductible payments to a nuclear plant decommissioning fund. The utility reported commission orders reallocating decommissioning costs among…
PLR 200544001: Parent company gets time to file dual consolidated loss forms
The parent of a consolidated corporate group discovered that it had omitted elections and annual certifications connected with losses of five disregarded entities. It said it had relied on…
PLR 200543065: IRA annuity cancellation receives late rollover waiver
An older IRA owner bought an IRA annuity on a bank officer's advice, then canceled it after a friend reviewed the contract. The insurer returned the money directly to the owner, who placed it in…
PLR 200543064: Widow may roll over her share of an IRA paid to a trust
A deceased IRA owner's trust was named as beneficiary, and its trustee, the owner's widow, mistakenly directed the full IRA balance into a regular account. The IRS found that she did not own the…
PLR 200543063: Hurricane relief supports a late IRA rollover
A taxpayer withdrew money from an IRA to document assets and pay costs for a home purchase, expecting to replenish the IRA after selling a Florida home. Hurricane damage delayed the sale, and the…
PLR 200543062: Employer's late separate business line notice is treated as timely
An employer operated separate business lines but missed the deadline to notify the IRS that it would use the qualified separate lines of business rules for an employee benefit plan. It had relied on…
PLR 200543061: Early trust termination avoids self-dealing and termination taxes
A charitable remainder unitrust proposed to end early and divide its assets between its lifetime income beneficiaries and charitable remainder beneficiaries. All beneficiaries consented, and 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.