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 200524026: Foundation may divide its assets among four other foundations
A private foundation's directors disagreed about grantmaking and investments, so they planned to distribute all its assets in four shares to four other private foundations. The IRS ruled that the…
PLR 200524025: Foundation may divide its assets among four other foundations
A private foundation's directors disagreed about grantmaking and investments, so they planned to distribute all its assets in four shares to four other private foundations. The IRS ruled that the…
IRS 200524024: Organization loses exemption after failing to provide records
The IRS asked an exempt organization for records about its activities and finances so it could determine whether the organization still met the IRC § 501(c)(3) requirements. The organization…
PLR 200524023: Foundation may divide its assets among four other foundations
A private foundation's directors disagreed about grantmaking and investments, so they planned to distribute all its assets in four shares to four other private foundations. The IRS ruled that the…
PLR 200524022: Corporation receives relief for a late S election
A corporation's shareholder wanted S corporation treatment from the date the corporation was formed, but the appropriate IRS service center did not receive an S election. The IRS found reasonable…
PLR 200524021: Corporation may file a late S election within 60 days
A corporation's shareholders intended to elect S corporation treatment from the date of incorporation, but its Form 2553 was not filed on time. The IRS found reasonable cause for the late election…
PLR 200524020: Unequal shareholder payments do not end S corporation status
An S corporation paid certain shareholder tax liabilities directly to government entities. Those payments were unequal relative to the shareholders' ownership interests, even though ordinary…
PLR 200524019: Stock distribution ends three gain recognition agreements
A U.S. corporate group transferred three domestic subsidiaries through mergers and received stock of a foreign corporation. The group filed three gain recognition agreements, which could require…
PLR 200524018: Partnership gets 60 more days to make a basis adjustment election
A limited liability company treated as a partnership missed the deadline to elect a partnership property basis adjustment under IRC § 754 after a partner died. It requested an extension under the…
PLR 200524017: County deferred compensation plan qualifies, with spouse provision caveat
A county asked whether its employee deferred compensation plan qualified under IRC § 457(b) and counted as a retirement system for Social Security tax purposes. The IRS said it did, and that…
PLR 200524016: County deferred compensation plan qualifies with spouse provision caveat
A county asked whether its employee deferred compensation plan qualified under IRC § 457(b). The IRS ruled that it did and that deferred compensation and its earnings would generally enter a…
PLR 200524015: Public gas agency and subsidiary receive governmental tax treatment
An agency formed by political subdivisions to acquire and manage natural gas supplies sought rulings for itself and its wholly owned subsidiary. The IRS found both to be instrumentalities of the…
PLR 200524014: Charitable remainder trust split and foundation gift approved
A taxpayer proposed dividing a charitable remainder unitrust into two trusts, then giving his payment interest in one trust to his family foundation, which would also receive that trust's remainder.…
PLR 200524013: Splitting a charitable remainder trust into two approved
A married couple proposed dividing their charitable remainder unitrust equally into two trusts, each centered on one spouse while preserving a survivor's payment interest. The IRS ruled that the…
PLR 200524012: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524011: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524010: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524009: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524008: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524007: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524006: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524005: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524004: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524003: Corporate restructuring and split-off receive tax-free treatment
A group of closely held corporations proposed mergers, subsidiary liquidations, asset contributions, and two stock distributions to separate businesses. The IRS gave rulings on the federal income…
PLR 200524002: Family trust divisions preserve generation-skipping tax exemption
A trustee sought to divide three family trusts into smaller trusts for distinct family branches, after obtaining contingent court approval. The IRS ruled that the amendments and proportional…
CCA 200524001: Self-employed health insurance deduction tied to one business
Chief Counsel advised that a sole proprietor may deduct qualifying health insurance costs under IRC § 162(l) even when the policy is issued in the proprietor's own name rather than the business's…
PLR 200523035: Utility recovery financing does not create immediate gross income
An electric utility sought a supplemental ruling after changes to a plan for recovering previously unrecovered costs through customer charges and bonds. The IRS ruled that a state financing order…
PLR 200523034: Pension plan receives minimum funding waiver
The IRS granted a company a waiver of the minimum funding standard for its defined benefit pension plan for the year ended December 31, 2003. The waived amount was the contribution otherwise needed…
PLR 200523033: Pension contributions deductible in designated tax years
A company planned contributions to four defined benefit pension plans after the close of 2004, with some designated for 2004 and the rest for 2005. The IRS ruled that contributions designated and…
PLR 200523032: Late IRA rollover accepted after check delay
A taxpayer directed an IRA distribution to an outside account, then asked within the 60-day period to return an equivalent amount to his IRA. The person responsible for issuing the replacement check…
PLR 200523031: Late IRA rollover accepted after mailing errors
A taxpayer took two distributions from his IRA and mailed a check with instructions to redeposit their combined amount within the 60-day rollover period. He omitted the financial advisor's suite…
PLR 200523030: IRA rollover deadline waived after account deposit error
A taxpayer asked a financial company to roll distributions from three IRAs into another IRA. The company instead deposited the proceeds into her regular account, and the mistake was discovered after…
PLR 200523029: Surviving spouse gets time to replace late IRA distribution
A taxpayer withdrew funds from his IRA to cover medical expenses while awaiting insurance payments. He intended to replace the funds, but serious cancer and repeated hospitalizations kept him from…
PLR 200523028: IRA owner gets more time after custodian ignores rollover instructions
An IRA owner moved her IRA assets and a separate account into a trust account that was not an IRA. About 18 days later, she told the financial company in writing to move the IRA assets into a…
PLR 200523027: Brain cancer patient receives more time to roll over retirement plan distribution
An employee with brain tumors withdrew a lump sum from his employer's qualified retirement plan while his decision making was impaired. He never cashed the distribution check. His daughter, who…
PLR 200523026: Caregiver receives IRA rollover deadline waiver
An IRA owner received checks when certificates of deposit in two IRAs matured. She intended to move the money into new IRAs and did not cash the checks. Her father's serious illness and need for…
PLR 200523025: State plan may transfer 401(k) funds to buy pension service credit
A state asked whether participants in its 401(k) plan could direct transfers to its governmental defined benefit plans to buy additional service credit. The money would move directly between plan…
IRS determination 200523024: Financial coaching group denied tax exemption over private benefit
A financial coaching group sought exemption under IRC § 501(c)(3), citing public education and counseling. The IRS found that it received its clients and projected first year revenue from an…
TAM 200523023: Housing project loans retain different subsidy treatment
A low-income housing project received two noninterest-bearing loans from its general partner, one funded by a federal HOME grant and the other by Affordable Housing Program funds. The IRS treated…
PLR 200523022: Corporation gets time to file dual consolidated loss documentation
A U.S. consolidated group had elected to use losses from a foreign separate unit. After the unit sold all its assets to an unrelated party, the group failed to attach documentation to its return to…
PLR 200523021: Group gets time to file dual consolidated loss recapture statements
A U.S. consolidated group changed a foreign entity's classification from a partnership to a corporation, causing a triggering event under the dual consolidated loss regulations. Its former…
PLR 200523020: Group gets time to document foreign branch asset sales
A U.S. consolidated group had foreign branches whose assets were transferred or sold, including sales to unrelated buyers. The transactions raised triggering event issues under the dual consolidated…
PLR 200523019: Group gets time to file dual consolidated loss certifications
A U.S. consolidated group had not filed annual certifications for two years after using dual consolidated losses from a foreign hybrid entity. The group said its former accounting firms neither…
PLR 200523018: S corporation gets time to elect QSub status for ten subsidiaries
An S corporation intended to treat ten wholly owned subsidiaries as qualified subchapter S subsidiaries, or QSubs, but inadvertently missed the election filings. It represented that its returns had…
PLR 200523017: Partnership gets time to make basis adjustment election
A partnership failed to make an IRC § 754 election with its return for the year in which a partner died. That election can adjust the basis of partnership property following a transfer of a…
PLR 200523016: Corporation receives relief for late S election
A corporation intended to elect S corporation status when it was incorporated but did not file the election on time. The IRS found reasonable cause for the missed deadline under IRC § 1362(b)(5). It…
PLR 200523015: Estate gets time to complete farmland valuation election
An estate had made a protective election to value family farmland under IRC § 2032A but missed the 60-day period to complete it after receiving an estate tax closing letter. Its accountant had not…
PLR 200523014: Foreign company gets time to elect disregarded entity status
Investors acquired foreign subsidiaries and intended one company to be disregarded as separate from its owner for U.S. tax purposes from the acquisition date. The company inadvertently failed to…
PLR 200523013: S corporation status restored after trusts miss income distributions
Several trusts that held an S corporation's shares failed to distribute all their income for one year as required for qualified subchapter S trusts. The IRS concluded that this failure terminated…
PLR 200523012: Local governments' power buying group receives income exclusion
Local governments formed an association to buy electricity and related services jointly. Its members controlled it, funded its costs, and would receive its remaining funds on termination; private…
PLR 200523011: S corporation status continues after missed trust election
An S corporation's shares passed from an eligible shareholder trust to a second trust after the original owner's death. The beneficiary of the second trust did not know to file a qualified…
PLR 200523010: S corporation status continues after missed trust election
An S corporation's shares passed from an eligible shareholder trust to a second trust after the original owner's death. The beneficiary of the second trust did not know to file a qualified…
PLR 200523009: Late application to change tax year treated as timely
A taxpayer filed Form 1128 late to request a change from a December 31 tax year end to March 31. It attributed the missed deadline to an error or misunderstanding and sought relief within 90 days of…
PLR 200523008: Company receives relief for late tax year change application
After a change in ownership, a company sought to align its tax year with its new owner's year. Communication problems between its former and new tax advisers delayed Form 1128 and its relief request…
PLR 200523007: Sale of former partners' contingent rights creates no debt cancellation income
Former partners held contingent rights to recover capital contributions after a project became operational and the partnership could pay without undue hardship. The project had never become…
PLR 200523006: S status continues after conversion adds ineligible partner
An S corporation converted into a limited partnership while retaining corporate tax classification. Its S election terminated when an ineligible entity became the general partner, and the conversion…
PLR 200523005: Controlled group may revoke alternative research credit election
A corporation and its controlled group had elected to calculate their research credit under the alternative incremental research credit rules. Before the return deadline for a later year, the…
PLR 200523004: Corporation receives relief for a late S corporation election
A corporation's shareholders intended it to be an S corporation when it was formed, but its Form 2553 election was not filed on time. The IRS found reasonable cause for the missed deadline and…
PLR 200523003: Family trust company may serve as trustee without triggering specified trust and estate tax consequences
A family planned to appoint its trust company as trustee of several family trusts after changing the trust agreements. The company's rules barred trust donors and beneficiaries, and people related…
PLR 200523002: Company receives more time to elect corporate status for foreign entity
A U.S. corporation intended to elect corporate tax status for a foreign entity it owned through intermediaries, but missed the Form 8832 filing deadline through inadvertence. It requested 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.