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 200502035: Sale proceeds retain pre-1990 Chapter 14 treatment
Before October 8, 1990, family members acquired real property as life tenants and remainder owners and agreed how sale proceeds would be held in trust. They proposed selling one property to an…
PLR 200502034: Late dual consolidated loss filings receive 45-day extension
A corporation learned that its application to extend the filing deadline for its consolidated return had arrived late. Its related election agreements and annual certifications under the dual…
PLR 200502033: Late dual consolidated loss filings receive 45-day extension
A corporation learned that its Form 7004 request to extend the filing deadline for a consolidated return had not arrived on time. It then determined that related election agreements and annual…
PLR 200502032: Trust split and unitrust conversion preserve GST exemption
Trustees divided a trust that was irrevocable before September 25, 1985 into three fractional subtrusts for different great-grandchildren. They also converted the income trust to a total return…
PLR 200502031: Testamentary trust split preserves GST exemption
A trust created under a will before September 25, 1985 was divided fractionally into three subtrusts for different great-grandchildren. The trustees also converted the income trust into a total…
PLR 200502030: Late S corporation election receives relief
A corporation intended to elect S corporation status from its incorporation date but missed the filing deadline. It asked the IRS to treat its election as timely under section 1362(b)(5). The IRS…
PLR 200502029: Late accounting period change application treated as timely
A taxpayer sought to change from a calendar tax year to a year ending January 31 but filed Form 1128 shortly after its deadline because of an error or misunderstanding. The IRS found that the…
PLR 200502028: Research credit election revocation allowed for later year only
A corporation had elected to calculate its research credit under the alternative incremental research credit rules. It asked to revoke that election for one tax year, or alternatively for a later…
PLR 200502027: Missed S corporation election receives reasonable-cause relief
A newly incorporated company intended to be taxed as an S corporation from its incorporation date but did not file its election on time. It asked the IRS for late-election relief under section…
PLR 200502026: Late S corporation election effective from incorporation
A company intended to elect S corporation status from the date it was incorporated, but its election was late. It requested relief under section 1362(b)(5). The IRS found reasonable cause for the…
PLR 200502025: Late S corporation election accepted for requested date
A corporation intended to be taxed as an S corporation beginning on a specified date after its incorporation, but did not file Form 2553 on time. It requested late-election relief under section…
PLR 200502024: Missed trust election gets inadvertent S termination relief
An S corporation shareholder gave shares to a trust, but the trust beneficiary did not timely elect qualified subchapter S trust status. That omission terminated the corporation's S election when…
PLR 200502023: Synthetic fuel partnership retains section 29 credit rulings
A partnership that produced synthetic fuel from coal sought confirmation of earlier section 29 credit rulings after changing chemical reagents and adding partners. Following its stated ruling…
PLR 200502022: Coal-derived fuel partnership confirms section 29 credits
A partnership producing synthetic fuel from coal asked the IRS to confirm earlier section 29 credit rulings after changing its chemical reagents and bringing in new partners. Under the IRS's stated…
PLR 200502021: LLC conversion receives classification and S status relief
An S corporation merged into a limited liability company owned by its shareholders. The company intended to be classified as a corporation but failed to file Form 8832; its operating agreement also…
PLR 200502020: Sole-shareholder corporation gets late S election relief
A corporation's sole shareholder said the company intended S corporation status from its incorporation date, but it did not timely file Form 2553. The corporation requested relief under section…
PLR 200502019: Partnership interest transfers do not restart building's ten-year clock
A buyer planned to acquire and rehabilitate an existing apartment building for low-income housing credits. It needed at least ten years between its purchase and the building's last placement in…
PLR 200502018: Trustee succession changes preserve GST exemption
A beneficiary of a trust irrevocable before September 25, 1985 sought court instructions limiting self-distributions if a beneficiary served as trustee and changing the order for successor trustees.…
PLR 200502017: Successor trustee changes leave GST exemption intact
A beneficiary of a trust irrevocable before September 25, 1985 petitioned a court to accept a trustee's resignation, change the successor order, and limit self-distributions if a beneficiary became…
PLR 200502016: Business separation receives spin-off reorganization rulings
A corporation planned to place one of its two businesses into a new company and distribute that company's shares pro rata to its shareholders. The IRS ruled that the contribution and distribution…
PLR 200502015: Sole-shareholder company receives late S election relief
A sole shareholder intended a newly incorporated company to be an S corporation, but the company's Form 2553 was not filed on time. The IRS found reasonable cause for the late election under section…
PLR 200502014: Retained appointment power leaves gift to trust incomplete
A person proposed funding a trust that could benefit that person and family members, while retaining a testamentary limited power to change who would ultimately receive trust property. The IRS ruled…
PLR 200502013: Off-site parking payments count toward co-op income test
A cooperative housing corporation without an on-site garage proposed leasing spaces in nearby garages for its resident shareholders. The residents would reimburse the corporation through their…
PLR 200502012: Open-space land rights yield different bond private-use results
A public authority planned to finance land rights for an open-space program with bonds while allowing some agricultural activity. The IRS found no private business use when the authority bought a…
PLR 200502011: Missed dual consolidated loss filings get 45-day extension
A corporate group's review of prior consolidated returns revealed that it needed to file election agreements and annual certifications under the dual consolidated loss rules for listed entities and…
PLR 200502010: Shareholder split-off receives reorganization rulings
A corporation planned to put one business into a new company and transfer all of that company's stock to withdrawing shareholders in exchange for their shares in the original corporation. It also…
PLR 200502009: Family property proceeds retain pre-1990 Chapter 14 status
A family bought real property before October 8, 1990, dividing ownership between life tenants and remainder owners under an agreement governing any later sale proceeds. The family proposed selling…
PLR 200502008: Pre-1990 family property retains Chapter 14 treatment after sale
Before October 8, 1990, spouses and their children bought real property as life tenants and remainder owners, each paying for their interest. Their agreement required proceeds from a sale to be held…
PLR 200502007: Utility receives revised nuclear decommissioning funding schedule
A regulated utility sought revised annual ruling amounts for its qualified nuclear decommissioning fund after two public utility commissions set the decommissioning costs included in customer rates.…
PLR 200502006: Dual citizen's submission rebuts expatriation presumption
A lifelong dual citizen relinquished U.S. citizenship while her net worth exceeded the threshold for a presumed tax-avoidance purpose under section 877. She requested a ruling based on her dual…
PLR 200502005: Late corporate, S, and QSub elections receive filing relief
An eligible entity intended to be taxed as a corporation and an S corporation from its formation date, with its wholly owned subsidiary treated as a qualified subchapter S subsidiary. It discovered…
PLR 200502004: Aircraft's original use began with its final purchaser
A corporation asked whether it was the original user of an aircraft for the 50 percent first year depreciation deduction. An earlier buyer had accepted the aircraft but never physically possessed or…
PLR 200502003: Late controlled foreign corporation election receives filing relief
A taxpayer inadvertently failed to file an election statement for its controlled foreign corporation under the foreign base company income rules. It requested more time to make the regulatory…
PLR 200502002: Disability service benefits excluded from recipients' income
A nonprofit regional center used state funds to provide transportation and respite care for people with developmental disabilities and other qualified individuals. It delivered the help through…
PLR 200502001: Late dual consolidated loss certifications receive filing relief
A corporation discovered that it had missed annual certifications for foreign entities' dual consolidated losses. The IRS found that the requirements for late regulatory election relief were met and…
PLR 200501025: Corporate separation receives spin-off and reorganization rulings
A publicly traded corporation planned to separate two businesses through a series of subsidiary transfers and distributions, a public offering of some Controlled stock, and a distribution of its…
PLR 200501024: Defined benefit plan receives minimum funding waiver
A nonprofit corporation received a waiver of the minimum funding standard for its defined benefit pension plan for the plan year ended December 31, 2003. The corporation reported falling revenue and…
PLR 200501023: Pension funding waiver granted subject to bankruptcy conditions
A company in Chapter 11 bankruptcy received a conditional waiver of its pension plan's minimum funding standard for the 2003 plan year. The company described financial hardship after an accident and…
PLR 200501022: Foundation's securities lending program avoids self-dealing
A private foundation proposed paying its investment trustee to arrange loans of the foundation's securities to outside borrowers. The trustee would act as the foundation's agent, and neither it nor…
PLR 200501021: Foundation's securities lending program avoids self-dealing
A private foundation proposed paying its investment trustee to arrange loans of the foundation's securities to outside borrowers. The trustee would act as the foundation's agent, and neither it nor…
Ruling 200501020: Applicant denied social welfare tax exemption
An applicant sought exemption from federal income tax as a social welfare organization under § 501(c)(4). The IRS issued a final adverse ruling because the applicant had not established that it…
PLR 200501019: Half of a foundation's assets may pass to another foundation
A private foundation proposed transferring half its assets to another private foundation so the recipient could support charities in a different community. The IRS ruled that the transfer qualified…
PLR 200501018: Half of a foundation's assets may pass to another foundation
A private foundation proposed transferring half its assets to another private foundation so the recipient could support charities in a different community. The IRS ruled that the transfer qualified…
PLR 200501017: Insurance for taxable subsidiary preserves exemption but creates taxable income
A hospital's exempt self-insurance trust proposed covering the risks of the hospital's for-profit nursing home subsidiary. The trust asked whether this would affect its § 501(c)(3) exemption or §…
TAM 200501016: Furniture seller must report combined cash installment payments
A furniture retailer received cash installments for purchases of multiple items whose combined price exceeded $10,000. Different employees collected the payments, but a central system posted them to…
PLR 200501015: Corporation receives relief for missed S election
A corporation's sole shareholder intended to elect S corporation treatment from its incorporation date, but no Form 2553 was filed. The IRS found reasonable cause for the omission under §…
PLR 200501014: S corporation, trust, and subsidiary elections receive relief
A corporation missed its initial S election and later transferred shares to two trusts that had missed the elections needed to be eligible S corporation shareholders. It also failed to elect…
PLR 200501013: S election survives temporary IRA ownership of shares
An S corporation issued shares to an individual's IRA, which was not an eligible S corporation shareholder. After discovering that this had terminated its S election, the corporation redeemed the…
PLR 200501012: Foreign entity receives time to elect partnership classification
A foreign entity whose shareholders all had limited liability intended to elect partnership classification when it adopted new articles of association. Its tax adviser failed to file Form 8832. The…
PLR 200501011: S status preserved until corporation's acquisition
An S corporation's shareholders transferred shares to two trusts that had not made the elections needed to be eligible S corporation shareholders. The transfers ended the corporation's S election.…
PLR 200501010: Late S corporation election treated as timely if filed within 60 days
A corporation intended to be an S corporation from its incorporation date, but did not file Form 2553 on time. The IRS found reasonable cause for the missed election under § 1362(b)(5). It ruled…
PLR 200501009: Synthetic fuel partnership retains § 29 credit after changes
A partnership sought confirmation of earlier § 29 fuel credit rulings after changing chemical reagents and admitting new partners. The IRS ruled that its described process would produce qualified…
PLR 200501008: Foreign subsidiary receives late disregarded entity election relief
A foreign limited company owned by another foreign company treated as a partnership intended to elect disregarded entity status from its formation date. It missed the deadline for Form 8832. The IRS…
PLR 200501007: Corporation receives relief for late S election
A corporation intended to elect S corporation treatment from its incorporation date but did not file Form 2553 on time. The IRS found reasonable cause for the missed filing under § 1362(b)(5). It…
PLR 200501006: Trustee change preserves trust's GST exemption
A trust created before the generation-skipping transfer tax grandfather date sought court instructions limiting distributions by a trustee who was also a beneficiary, plus a new trustee succession…
PLR 200501005: Late dual consolidated loss statements receive filing relief
A corporation's in-house tax staff overlooked statements required by the dual consolidated loss regulations. The omission came to light during a review following an acquisition of another…
PLR 200501004: Utilities may share bond-financed generator components
Three public utilities planned to pool interchangeable generator components, including parts financed with tax-exempt bond proceeds, to reduce maintenance costs. A service provider would refurbish…
PLR 200501003: Utilities may share bond-financed generator components
Three public utilities planned to pool interchangeable generator components, including parts financed with tax-exempt bond proceeds, to reduce maintenance costs. A service provider would refurbish…
PLR 200501002: LLC receives time to elect corporate tax treatment
An LLC intended to elect treatment as a corporation for federal tax purposes but did not file Form 8832 on time. It requested a late regulatory election under Treas. Reg. § 301.9100-3. The IRS found…
CCA 200501001: Conflicting evidence leaves LLC ownership unresolved
IRS counsel was asked whether an LLC should be treated as having one owner or multiple owners for federal tax purposes. The founder had at one point described his father as a member, while 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.