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 200521001: Estate receives more time to elect family business deduction
An estate had considered the qualified family-owned business interest deduction but did not elect it after concluding that it failed the threshold requirements. An audit later indicated that the…
PLR 200520040: Pension funding and excise tax waivers granted with conditions
A plastic products manufacturer sought relief for funding deficiencies in its hourly and salaried pension plans. The IRS conditionally waived the minimum funding standard for one plan year and the…
PLR 200520039: Public academy employee plan qualifies as a governmental plan
An academy established by state legislation asked whether its employee retirement plan was a governmental plan under IRC § 414(d). The academy provided public secondary education to students from…
PLR 200520038: Survivor receives more time to complete deceased spouse's IRA rollover
A woman received a distribution from her IRA intending to move it to another IRA, but died before the 60-day rollover period expired. Her surviving spouse tried to redeposit the money, and the bank…
PLR 200520037: IRA rollover deadline waived after deposit into wrong accounts
An IRA owner withdrew funds intending to roll them into another IRA and deposited the same amount that day into two bank certificates of deposit. The owner believed the accounts were IRAs because…
PLR 200520036: University retirement plan has governmental status and picked up contributions
A state university established an alternative retirement plan for eligible employees and asked how its employee contributions would be treated. The IRS concluded that the university was a state…
TAM 200520035: Foreign reinsurer loses small insurer exemption
A foreign corporation elected domestic treatment and obtained recognition as a tax exempt small insurance company. Its limited assumed insurance risks and premium income were minor beside income and…
Determination 200520034: Fraternal society's tax exemption revoked after bingo became its main activity
The IRS revoked a fraternal association's exemption under IRC § 501(c)(8), effective January 1, 1999. An audit found that bingo had become its main activity, while its fraternal activities and…
Determination 200520033: IRS proposes an adjustment to an organization's exempt status
The IRS told an organization that an examination report recommended adjusting its exempt status. The letter offers an administrative appeal and explains how to request technical advice. If the…
PLR 200520032: Fee based insurance consulting in developing countries did not qualify as charity
An organization applied for charitable tax exemption to help financial institutions and insurers create low cost insurance products for people in developing countries. It planned to research markets…
Determination 200520031: IRS proposes an adjustment to an organization's exempt status
The IRS told an organization that an examination report recommended adjusting its exempt status. The letter explains how the organization can appeal or request technical advice. It says that…
Determination 200520030: IRS proposes to revoke an organization's charitable exemption
The IRS proposed revoking an organization's exemption under IRC § 501(c)(3), referring it to an enclosed examination report. The organization could request Appeals Office review within 30 days or…
CCA 200520029: IRS withdraws earlier railroad employer status determination
The Railroad Retirement Board reconsidered a prior determination about a business's status under the Railroad Retirement Act and Railroad Unemployment Insurance Act and recommended revoking it.…
CCA 200520028: Business continues to have railroad employer status
On reexamination, the Railroad Retirement Board concluded that a business continued to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. IRS Chief Counsel…
CCA 200520027: Business is not a railroad employer; worker status remains unresolved
The Railroad Retirement Board concluded that a business was not an employer under the Railroad Retirement Act or Railroad Unemployment Insurance Act. IRS Chief Counsel agreed that it was not an…
CCA 200520026: Business became a railroad employer under the tax act
The Railroad Retirement Board concluded that a business became an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. IRS Chief Counsel reviewed the Board's opinion…
CCA 200520025: Farm price inventory method must track animals' growth in value
A producer changed to the farm price method for its live animal inventories under an IRS consent agreement. The agreement required the value of animals raised for sale or slaughter to increase on a…
PLR 200520024: Former citizen rebuts presumption of tax motivated expatriation
A former U.S. citizen asked the IRS to rule that giving up his citizenship was not principally intended to avoid U.S. taxes. His net worth exceeded the threshold that would normally trigger a…
PLR 200520023: Transfer to replacement trust preserves generation skipping tax exemption
A grantor created three irrevocable trusts before September 25, 1985, for the grantor's children. A court approved a plan to move their assets into replacement trusts that would continue to benefit…
PLR 200520022: Transfer to replacement trust preserves generation skipping tax exemption
A grantor created three irrevocable trusts before September 25, 1985, for the grantor's children. A court approved a plan to move their assets into replacement trusts that would continue to benefit…
PLR 200520021: Transfer to replacement trust preserves generation skipping tax exemption
A grantor created three irrevocable trusts before September 25, 1985, for the grantor's children. A court approved a plan to move their assets into replacement trusts that would continue to benefit…
PLR 200520020: Late S corporation election granted conditional relief
A corporation and its shareholder intended S corporation treatment from the start of business and filed their tax returns consistently with that intent. The corporation had failed to file its S…
PLR 200520019: Revised funding schedule approved for nuclear plant decommissioning
An owner of an interest in a nuclear plant requested a revised schedule of annual amounts for its decommissioning fund. The IRS approved the proposed schedule under IRC § 468A based on the utility…
PLR 200520018: Revised funding schedule approved for nuclear plant decommissioning
An owner of an interest in a nuclear plant requested a revised schedule of annual amounts for its decommissioning fund. The IRS approved the proposed schedule under IRC § 468A based on the utility…
PLR 200520017: Inadvertent shareholder transfer did not end S corporation treatment
An S corporation issued shares to an LLC owned by another S corporation. The LLC was an ineligible shareholder, so the transfer terminated the issuer's S election. After discovering the problem, the…
PLR 200520016: Former resident's expatriation found not tax motivated
A former long term U.S. resident surrendered his green card and sought a ruling about the tax purpose of his expatriation. His net worth exceeded the threshold that normally creates a presumption of…
PLR 200520015: Single member LLC receives late entity classification and S election relief
A single member LLC intended to be taxed as an S corporation from the date it was formed, but it missed both the entity classification election and the S corporation election. The IRS granted 60…
PLR 200520014: Employer retiree health fund payments excluded from income
An employer planned to set aside money to pay part of eligible retirees' health coverage under its existing health plan. The fund would be held by the employer, have no individual accounts, and pay…
PLR 200520013: Estate gets extension to divide trust for generation skipping tax election
An estate had made a reverse QTIP election for a marital trust and allocated part of the decedent's generation skipping transfer tax exemption to it. A later transitional regulation allowed that…
PLR 200520012: Foreign entity gets extension for disregarded entity election
A foreign entity with one owner intended to be treated as a disregarded entity for U.S. federal tax purposes, but it missed the deadline to file Form 8832. Its owner had limited liability, so the…
PLR 200520011: Ownership change testing may disregard relative stock value swings
A corporate group with common and preferred stock expected an ownership change when it emerged from bankruptcy. Its common stock had fallen in value relative to preferred stock, while shareholders…
PLR 200520010: Shorter annual withdrawal window preserves older trust's GST exemption
An irrevocable trust gave the settlor's daughter an annual right to withdraw the greater of $5,000 or five percent of the trust principal. The trustee proposed limiting her exercise of that right to…
PLR 200520009: Shorter annual withdrawal window preserves older trust's GST exemption
An irrevocable trust gave the settlor's daughter an annual right to withdraw the greater of $5,000 or five percent of the trust principal. The trustee proposed limiting her exercise of that right to…
PLR 200520008: Couple receives late GST exemption allocation relief for family trust
Two taxpayers funded an irrevocable trust for their children and descendants and reported the transfer on gift tax returns. Their accountant omitted allocations of their generation skipping transfer…
PLR 200520007: Late dual resident loss elections and certifications allowed
A corporation relied on its CPA firm to prepare consolidated tax returns but omitted elections, agreements, and annual certifications for an entity under the dual resident corporation loss rules.…
PLR 200520006: Foreign entity allowed late election for disregarded status
A foreign entity intended to be treated as disregarded from its owner for U.S. federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS concluded that it met the standards…
PLR 200520005: Updated state deferred compensation plan retains tax deferred status
A state updated its deferred compensation plan for participating public employers to reflect changes in § 457 rules. The IRS ruled that the plan, when adopted by eligible employers, qualified under…
PLR 200520004: Estate may assign retirement benefits to residuary charity without recognizing income
A decedent's estate was the beneficiary of several IRAs and a retirement plan. The will named a charity as a residuary beneficiary and allowed the executor to distribute assets in kind. The executor…
PLR 200520003: Pro rata trust division preserves GST exemption and avoids gain or gift
A trustee proposed dividing a pre-1985 irrevocable trust into four successor trusts for its current beneficiaries. Each would receive a proportionate share of the original trust's assets, with…
PLR 200520002: S corporation gets more time to elect subsidiary's QSub status
An S corporation bought all the stock of another corporation and intended to treat the subsidiary as a qualified subchapter S subsidiary, or QSub. It inadvertently failed to file the election. The…
PLR 200520001: Parent gets time to file subsidiary stock loss statement
A consolidated corporate group sold all the stock of a subsidiary in a taxable transaction. Its return treated a loss election as made, but the required statement was not attached. The IRS found…
CCA 200519091: Business ceased to be a railroad employer
The Railroad Retirement Board concluded that a business ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. IRS Chief Counsel reviewed the Board's…
Determination 200519090: IRS extends a deadline tied to pension funding waiver
The IRS had conditionally waived a pension plan's minimum funding standard in an earlier ruling. This letter modified that ruling by changing the deadline for an agreement with the Pension Benefit…
PLR 200519089: Medical hardships justify late IRA rollover waiver
An 80 year old IRA owner received a distribution to help his son, but the son resolved the problem independently. The funds remained intact while the owner underwent cancer treatment and cared for…
IRS determination 200519088: Religious networking site denied tax exemption
A nonprofit sought recognition as a religious organization under IRC § 501(c)(3). Its website and newsletter offered religious articles and fellowship, along with professional job listings,…
IRS determination 200519087: Fraternal society denied exemption without lodge system
A fraternal society applied for exemption under IRC § 501(c)(8). It held member meetings, visited sick and elderly members, attended funerals, and paid death and funeral benefits. The IRS found that…
PLR 200519086: Employee benefit association may use remaining funds for life insurance
An exempt employee benefit association proposed using its remaining assets to buy additional group life insurance for eligible employees, then terminating. The funds came mainly from a premium…
IRS determination 200519085: Golf club loses exemption after failing to track public use
A social club operated a nine hole golf course, bar, and restaurant used by members and nonmembers. The examination report says the club kept no records showing whether public use stayed within the…
IRS determination 200519084: Veterans' organization consents to proposed exemption revocation
The IRS proposed revoking an organization's exemption under IRC § 501(c)(19). The letter says the organization had already signed a consent to the proposed action, and it would become final if the…
PLR 200519083: State supervised workers' compensation fund need not file Form 990
A tax exempt workers' compensation organization asked whether it could skip its annual Form 990 under Revenue Procedure 95-48. A state government created it, the governor appointed most of its…
PLR 200519082: Court approved trust settlement does not trigger foundation self dealing tax
A private foundation had contingent interests in five family trusts whose current beneficiaries were relatives of a substantial contributor. After disputes over trust distributions, the parties…
CCA 200519081: IRS cannot refund embezzler's estimated tax payments to victim
An employee used embezzled funds to make estimated income tax payments on his own tax account. His former employer asked the IRS to return those funds directly, and the employee's estate released…
TAM 200519080: Workers' compensation fund gets different interest dates across tax years
A state created workers' compensation insurer paid estimated federal income tax while believing it was taxable, then received refunds after its income or status was found exempt for different years.…
CCA 200519079: Business is not a Railroad Retirement Tax Act employer
The Railroad Retirement Board told the IRS that a redacted business was not an employer under the Railroad Retirement Act or the Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
CCA 200519078: Business became a Railroad Retirement Tax Act employer
The Railroad Retirement Board told the IRS that a redacted business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
CCA 200519077: Business became a Railroad Retirement Tax Act employer
The Railroad Retirement Board told the IRS that a redacted business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
CCA 200519076: Business ceased being a Railroad Retirement Tax Act employer
The Railroad Retirement Board told the IRS that a redacted business had ceased being an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed…
CCA 200519075: Two businesses are not Railroad Retirement Tax Act employers
The Railroad Retirement Board told the IRS that two redacted businesses were not employers under the Railroad Retirement Act or the Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
CCA 200519074: Business became a Railroad Retirement Tax Act employer
The Railroad Retirement Board told the IRS that a redacted business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed the…
CCA 200519073: Business is not a Railroad Retirement Tax Act employer after reconsideration
On reconsideration, the Railroad Retirement Board told the IRS that a redacted business was not an employer under the Railroad Retirement Act or the Railroad Unemployment Insurance Act. Chief…
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.