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 200448021: Merging two older trusts preserves GST exemption and asset tax attributes
Two trusts created before September 25, 1985, had the same beneficiaries and nearly identical terms. Their trustees proposed merging them to reduce duplicate administration, subject to court…
PLR 200448020: Merging two older trusts preserves GST exemption and asset tax attributes
Two trusts created before September 25, 1985, had the same beneficiaries and nearly identical terms. Their trustees proposed merging them to reduce duplicate administration, subject to court…
PLR 200448019: Merging two older trusts preserves GST exemption and asset tax attributes
Two trusts created before September 25, 1985, had the same beneficiaries and nearly identical terms. Their trustees proposed merging them to reduce duplicate administration, subject to court…
PLR 200448018: Merging two older trusts preserves GST exemption and asset tax attributes
Two trusts created before September 25, 1985, had the same beneficiaries and nearly identical terms. Their trustees proposed merging them to reduce duplicate administration, subject to court…
PLR 200448017: Bond-funded generator purchase avoids output property restriction
A public authority used bond proceeds to buy two generator sets originally ordered by a private power producer. When the district bought the rights to the sets, their manufacturer had completed only…
PLR 200448016: Sole-shareholder company receives late S election relief
A corporation's sole shareholder intended the company to be an S corporation, but Form 2553 was not filed on time. The IRS concluded that there was reasonable cause for the missed deadline. It…
PLR 200448015: Historic building avoids tax-exempt use property treatment
A company planned to rehabilitate a historic building and develop an integrated group of buildings and facilities leased for government use. It asked whether the historic building would be…
PLR 200448014: Foreign company gets more time to elect corporate tax status
A foreign limited liability company converted to an unlimited liability company and wanted U.S. tax treatment as a corporation from the conversion date. It inadvertently failed to file Form 8832 on…
PLR 200448013: U.S. parent can liquidate into foreign parent without immediate gain
A domestic parent company proposed a complete liquidation that would distribute stock of its U.S. subsidiaries to a foreign parent through a foreign entity disregarded for U.S. tax purposes. Section…
PLR 200448012: Spouses' company receives relief for a late S election
A company's shareholders, spouses with community property interests in its stock, intended S corporation status from a specified date. Form 2553 was not filed on time. The IRS found reasonable cause…
PLR 200448011: Actively managed commercial rents are not passive investment income
A commercial real estate company planned to elect S corporation status and had accumulated earnings from its prior C corporation years. It asked whether rent from its properties would count as…
PLR 200448010: Missed trust election does not permanently end S status
An S corporation's stock was held by a trust that had been a grantor trust. Two years after the grantor died, the trust needed a qualified subchapter S trust election to remain an eligible…
PLR 200448009: Subsidiaries are treated as joining parent's consolidated returns
A parent company formed two corporate subsidiaries, but its outside accountant mistakenly treated them as limited liability companies that could be disregarded for tax purposes. The parent included…
PLR 200448008: Payments to extend gas lines are taxable construction contributions
A regulated natural gas distributor received payments from consumers, developers, and a universal service fund to extend gas lines to new locations. It argued that the payments should be excluded…
PLR 200448007: Corporation gets relief for a late first-year S election
A corporation intended to elect S status for its first taxable year, and its board meeting records showed that intent. It did not file Form 2553 on time. The IRS found reasonable cause for the…
PLR 200448006: Farm partnership valuation carries into GST trust funding
An estate held interests in a farming partnership and elected special use valuation for qualifying farm property under Section 2032A. To value the partnership interests, it first applied appropriate…
PLR 200448005: Utility receives revised nuclear decommissioning fund schedule
A utility sought a revised IRS schedule for payments to a nuclear plant decommissioning fund for a period before it transferred its plant interest to a related company. The public utility commission…
PLR 200448004: Company that filed as an S corporation gets election relief
Two shareholders intended their corporation to have S status from its incorporation date, and the company filed S corporation returns while they filed their own returns consistently. The company had…
PLR 200448003: S corporation receives relief after partnership bought its stock
An S corporation's stock was purchased by a limited liability company taxed as a partnership, which could not be an eligible S corporation shareholder. Its owners later distributed the stock to…
PLR 200448002: Nuclear plant sale transfers decommissioning funds with specified tax treatment
A utility agreed to sell its nuclear plant and transfer its decommissioning funds while the buyer assumed the duty to decommission the plant. The IRS allowed the qualified fund assets to move to the…
PLR 200448001: Converting an older trust to unitrust payments preserves GST treatment
A trust that became irrevocable before September 25, 1985, proposed changing a daughter's income-only interest to annual payments based on a percentage of trust assets, or the trust's income if…
PLR 200447051: Failed direct rollover receives a new 60-day deadline
An employee asked her former employer to roll a retirement plan distribution directly into her IRA and completed forms with the employer and credit union. Both institutions assured her it would…
Other 200447050: Fundraising for founder's daughter does not qualify as charity
A nonprofit sought recognition as a section 501(c)(3) charity and planned to raise money for a child injured in a pool accident. Its flyers sought donated items for a garage sale, with proceeds…
Other 200447049: School's related board and property transactions defeat exemption
A school and child care organization applied for recognition as a section 501(c)(3) charity. The IRS proposed denying exemption because its articles did not limit its purposes to exempt activities…
Other 200447048: Merchant discount and advertising programs fail charity test
A group created by local merchants sought recognition as a section 501(c)(3) charity for its economic development activities in a distressed area. Its main program offered consumers discounts at…
Other 200447047: Proposed denial for Christian retreat on directors' property
A Christian retreat organization sought recognition as a section 501(c)(3) charity. Guests could use religious books and videos, but the retreat had no scheduled religious activities and guests were…
Other 200447046: Credit repair service denied charitable exemption
An organization that sold credit repair and consultation services applied for section 501(c)(3) exemption. It also described plans for financial education, counseling, and help with basic needs. The…
PLR 200447045: Conditional waiver of a pension plan's funding standard
A family owned foundry requested a waiver of the minimum funding standard for its pension plan for the 2003 plan year. The company reported losses and difficulty raising capital after a downturn in…
PLR 200447044: Security condition revised for pension funding waiver
The IRS had granted a conditional minimum funding waiver for a pension plan in an earlier ruling. The taxpayer asked to change the condition because it needed approval from the Department of Housing…
PLR 200447043: Conditional pension funding waiver granted
The IRS granted a conditional waiver of the minimum funding standard for a company's pension plan under section 412(d). The company reported financial hardship, including net losses, negative…
PLR 200447042: IRA rollover deadline waived after a check was not received
A bank liquidated the taxpayer's IRA after resigning as trustee and issued a distribution check, but the taxpayer said the check and the bank's notices never arrived. The bank confirmed the check…
PLR 200447041: Rollover deadline waived for employer stock sent to the wrong company
After leaving an employer, a taxpayer requested a direct rollover of an entire retirement plan balance, including employer stock, to an IRA. The cash portion reached the IRA, but an internal error…
PLR 200447040: Disclaimers let surviving spouse inherit estate and roll over pension benefits
A deceased employee had revoked a trust named as beneficiary of his state retirement and deferred compensation plans without naming a replacement. The plan benefits therefore became payable to his…
PLR 200447039: IRA rollover deadline waived after advisor deposited funds in a regular account
A taxpayer instructed an investment advisor to consolidate distributions from three IRAs into a new IRA. One distribution reached the new IRA, but the other funds were deposited in a regular…
Ruling 200447038: Private school denied tax exemption over nondiscrimination requirement
The IRS issued a final adverse ruling on a private school's application for exemption under section 501(c)(3). The school failed to establish that it operated in a racially nondiscriminatory manner,…
TAM 200447037: Consolidated group loss rules after acquiring a company with built-in gains
One consolidated corporate group acquired another group whose assets had built-in gains. The IRS advised how section 384 limits the use of losses against gains recognized after the acquisition. It…
CCA 200447036: Bankruptcy discharge revocation and the tax collection deadline
Chief Counsel considered a Chapter 7 case in which a debtor's discharge of a tax debt was later revoked. It advised that section 6503(h) does not keep the tax collection limitations period suspended…
CCA 200447035: Combat zone death relief and refund claim deadlines
Chief Counsel analyzed refund claims after a service member died while serving in a combat zone. Under section 692, the member's income tax relief reaches back to the first tax year in which he…
PLR 200447034: Late S corporation election accepted with a new Form 2553
A corporation's sole shareholder intended the company to be an S corporation, but its Form 2553 election was not filed on time. The IRS found reasonable cause under section 1362(b)(5) and allowed…
PLR 200447033: Court reformation of charitable trust does not defeat unitrust treatment
A donor intended to retain power to change a charitable remainder trust's charity beneficiaries and their shares, but that power was omitted from the signed trust document. A state court reformed…
PLR 200447032: Partition of grandfathered trust preserves GST tax exemption
A trust created before the federal generation-skipping transfer tax took effect was to be divided into two equal trusts, one for each family line. The new trusts would receive proportional shares of…
PLR 200447031: Tax treatment of a multistep corporate separation
Several related corporate groups proposed a series of asset contributions, stock distributions, a debt exchange, and partnership distributions to separate businesses. The IRS issued 47 rulings on…
PLR 200447030: Unused GST exemption covered transfers to two trusts
A decedent's executor filed an estate tax return without allocating the decedent's generation-skipping transfer (GST) tax exemption. The estate asked whether the unused exemption was automatically…
PLR 200447029: Extra time to allocate GST exemption to a trust
A taxpayer funded an irrevocable trust for her husband and descendants but did not file a gift tax return or allocate generation-skipping transfer (GST) tax exemption. Her drafting attorney had told…
PLR 200447028: Late application to change a corporation's tax year accepted
A subsidiary corporation wanted to change its tax year from an August 31 year-end to March 31 to match its ultimate parent. It filed the return for the proposed first year on time but missed the…
PLR 200447027: Revised funding schedule for nuclear plant decommissioning
A utility with an ownership interest in a nuclear power plant requested a revised schedule of amounts it could pay into its decommissioning fund. It supplied cost estimates and ratemaking…
PLR 200447026: Club membership basis equals its initiation fee
A tax-exempt membership organization proposed to transfer its assets and liabilities to a limited liability company, then liquidate and distribute the company interests to its members. It asked for…
PLR 200447025: Late S corporation election granted relief
A corporation's sole shareholder intended for it to be an S corporation, but the corporation did not file Form 2553 on time. The IRS found reasonable cause for the missed deadline under section…
PLR 200447024: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447023: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447022: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447021: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447020: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447019: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447018: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447017: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447016: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447015: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447014: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but it missed the deadline to file Form 8832. It represented that it was eligible to make the election.…
PLR 200447013: Foreign entity given more time for classification election
A foreign entity intended to elect treatment as a disregarded entity for federal tax purposes, but its Form 8832 was inadvertently filed late. It represented that it was eligible to make 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.