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 200426021: Late rollover allowed after advisers used a retail account
A retiree intended to roll a qualified plan distribution into an IRA or another eligible retirement account. Her financial advisers instead deposited the check into a retail account without her…
PLR 200426020: IRA rollover deadline waived after medical confusion
A retiree withdrew money from a traditional IRA and deposited it into a money market account at the same financial institution. Stress and confusion caused by a medical condition prevented her from…
PLR 200426019: Revised funding schedule approved for nuclear decommissioning fund
A utility with an ownership interest in a nuclear plant sought a revised schedule of deductible payments to its decommissioning fund. The IRS concluded that the proposed schedule met the…
PLR 200426018: Late progress expenditure election treated as timely
Two taxpayers rehabilitating a historic building claimed a rehabilitation credit for work done before the building was placed in service. Their return preparer did not advise them to make the…
PLR 200426017: City parking authority income excluded and gifts deductible
A city created a parking authority to develop and operate public parking facilities. The city appoints and oversees its board, and the authority's assets must go to the city if it dissolves. The IRS…
PLR 200426016: Relinquishing green card found unrelated to tax avoidance
A person who obtained a green card as a child later relinquished it and lived in the country where he was born and held citizenship. His net worth exceeded the threshold that could trigger a…
PLR 200426015: Developer gets 45 days for late alternative cost election
A real estate developer intended to elect the alternative cost method for a project with its first lot sales. It filed an initial return extension but inadvertently missed the second extension…
PLR 200426014: Synthetic fuel credit survives facility sale and relocation
A partnership planned to buy and relocate a facility that makes synthetic fuel from coal, then transfer ownership interests to an investor. The IRS gave favorable rulings on fuel qualification, the…
PLR 200426013: Estate receives time to split trust and make reverse QTIP election
An estate made a QTIP election for a trust but did not split it into GST exempt and nonexempt parts or make a reverse QTIP election. Its accountant had not advised the estate to take those steps.…
PLR 200426012: New owner may make late entity classification election
A foreign entity had elected to be disregarded for federal tax purposes and later came under new ownership. It wanted to elect association status before the usual 60-month waiting period expired,…
PLR 200426011: Tax exempt employer's deferred compensation plan qualifies under section 457
A tax exempt employer offered a deferred compensation plan to selected management and highly compensated employees. The plan limited deferrals and permitted distributions for specified events,…
PLR 200426010: Public academy income excluded as governmental income
A state chartered academy provided free public education for students in grades K through 12. It received most of its operating funds from state school aid and was overseen by a public university…
PLR 200426009: Planned loss of citizenship found unrelated to tax avoidance
A dual citizen planned to give up U.S. citizenship within a year of receiving the ruling. Her net worth exceeded the threshold that could trigger a tax avoidance presumption under the expatriation…
PLR 200426008: Spouses' different trusts avoid reciprocal trust inclusion
A husband and wife proposed separate irrevocable trusts, each initially holding insurance on its creator's life. They asked whether the reciprocal trust doctrine would cause either trust to be…
PLR 200426007: Trust severance preserves GST exemption without taxable exchange
A pre-September 25, 1985 trust held separate shares for three children. The trustees proposed to divide each child's share into two trusts based on how much of a withdrawal right the child had…
PLR 200426006: Trust severance preserves GST exemption without taxable exchange
A pre-September 25, 1985 trust held separate shares for three children. The trustees proposed to divide each child's share into two trusts based on how much of a withdrawal right the child had…
PLR 200426005: Trust severance preserves GST exemption without taxable exchange
A pre-September 25, 1985 trust held separate shares for three children. The trustees proposed to divide each child's share into two trusts based on how much of a withdrawal right the child had…
PLR 200426004: Late GST exemption allocation receives transfer date effect
A couple transferred securities to three trusts and intended to allocate GST exemption to those gifts. Their gift tax returns were filed late, so the allocations initially took effect when filed,…
PLR 200426003: Late GST exemption allocation receives transfer date effect
A couple transferred securities to three trusts and intended to allocate GST exemption to those gifts. Their gift tax returns were filed late, so the allocations initially took effect when filed,…
PLR 200426002: Late S corporation election treated as timely if filed within 60 days
A corporation and its sole shareholder intended S corporation status from the corporation's first tax year, but Form 2553 was not filed on time. The IRS found reasonable cause for the missed filing.…
PLR 200426001: Source of nonresident's U.S. pension payments determined
A nonresident alien had worked for the same employer both inside and outside the United States and was due a pension from a U.S. defined benefit plan. The IRS explained how to determine the U.S.…
PLR 200425052: Chamber merger preserves exemptions and creates no UBTI
Three tax exempt chambers of commerce planned to combine the activities of two chambers by merging one into the other, with the third organization continuing to coordinate their work. The IRS ruled…
PLR 200425051: Educational television funding avoids self dealing tax
A private foundation planned to fund educational television programs for the public, especially older viewers. Its trustee would host the programs without pay, and an independent producer would be…
PLR 200425050: Charity may market software through taxable subsidiary
A charity serving older adults developed software to track its services and planned to transfer the software to a wholly owned, taxable subsidiary for marketing. The IRS ruled that owning the…
PLR 200425049: Surviving spouse's IRA rollover treated as timely
After her husband died, a surviving spouse received his IRA proceeds in a money market account and later moved them into an IRA in her own name. An investment representative incorrectly told her the…
TAM 200425048: Aircraft management fees subject to air transportation tax
Owners of fractional interests in aircraft paid a company monthly management fees, flight use fees, and additional charges. The IRS concluded that the company provided taxable air transportation…
TAM 200425047: Tax treatment of exchanged frequent flyer miles
An airline exchanged rights to award frequent flyer miles with domestic and foreign partner airlines. The IRS treated these exchanges as payments in kind for mileage award rights. The payments were…
CCA 200425046: IRS advised against disclosure contract for patient records
During an audit, the IRS sought billing records containing patient information from a health care taxpayer. The taxpayer proposed a contract governing disclosure under HIPAA. Chief Counsel advised…
PLR 200425045: More time to elect a housing project's 40/60 set-aside
A low-income housing project intended to elect the 40/60 minimum set-aside under § 42(g)(1)(B) but failed to make the election properly. The IRS found that the taxpayer met the requirements for an…
PLR 200425044: Late S corporation election allowed with Form 2553 filing
A corporation's sole shareholder intended to elect S corporation status, but the corporation did not file Form 2553 on time. The IRS found reasonable cause for the late election under § 1362(b)(5).…
PLR 200425043: Partnership given time to elect corporate tax status
A general partnership that headed a consolidated corporate group had intended to be taxed as a corporation. Its counsel prepared an entity classification election, but Form 8832 was never filed. The…
PLR 200425042: Late tax year election treated as timely
A taxpayer hired a tax professional to file Form 8716, electing a tax year other than its required year, but the form was filed late because of the professional's error or misunderstanding. The IRS…
PLR 200425041: Separation of two businesses qualifies as a reorganization
An S corporation with two unrelated businesses planned to put one business in a new corporation and distribute the new company's stock equally to its two shareholders. The IRS ruled that the…
PLR 200425040: Controlled group may revoke research credit election
A corporation had elected the alternative incremental method for computing its research credit on behalf of itself and its controlled group. It asked to revoke that election for a later tax year.…
PLR 200425039: Managed property rents excluded from S corporation passive income
An S corporation owned and managed a property with several kinds of residential units. It provided extensive maintenance, utilities, on-site management, and common area services to occupants. The…
PLR 200425038: Extension to elect consolidated return filing
A parent corporation and its subsidiary missed the deadline to elect consolidated federal income tax return filing. The parent had reasonably relied on a tax professional who failed to make or…
PLR 200425037: Serviced property rents excluded from S corporation passive income
An S corporation leased and managed a property using employees shared with a sister company and independent contractors. They maintained buildings, grounds, roads, and utility systems and provided…
PLR 200425036: Managed property rents excluded from S corporation passive income
An S corporation rented property and shared employees with a sister company. Its staff and contractors maintained the buildings, laundry and pool facilities, roads, grounds, and private utility…
PLR 200425035: Partnership given time for a late basis adjustment election
A limited liability company taxed as a partnership intended to make a § 754 basis adjustment election for a year in which the grantor of a member trust died. It inadvertently missed the filing…
PLR 200425034: Estate granted more time to elect family business deduction
An estate wanted to claim the former § 2057 qualified family-owned business deduction, but its attorney omitted the election from Form 706. The IRS found that the estate had acted reasonably and in…
PLR 200425033: Family shareholder split-off qualifies as a reorganization
Two family shareholder groups disagreed over a closely held corporation's business. The corporation proposed transferring a business asset to a new corporation for its stock, assumption of related…
PLR 200425032: Late S election allowed if shareholders amend returns
Four shareholders intended for a corporation to be an S corporation from its formation, but Form 2553 was filed late. Two shareholders had filed returns for the first year consistent with S…
PLR 200425031: LLC granted relief for late corporate and S elections
The members of a limited liability company intended it to be taxed as a corporation and to elect S corporation status from its formation date. The company inadvertently failed to file both Form 8832…
PLR 200425030: Late S election allowed for stated effective date
A corporation's sole shareholder discussed an S corporation election with its accountant, but Form 2553 was not filed on time. The request described an intended election for one redacted tax year.…
PLR 200425029: Time allowed to sever QTIP trust and make reverse election
An estate claimed a marital deduction for a trust but did not file the schedule needed for a reverse QTIP election or expressly allocate the decedent's generation-skipping transfer (GST) exemption.…
PLR 200425028: More time for dual consolidated loss filings
A taxpayer's tax professionals inadvertently failed to prepare election agreements and annual certifications for specified dual consolidated losses of two entities' separate units. The IRS concluded…
PLR 200425027: Reformed charitable trust receives estate deduction and plan proceeds
A decedent's will directed the estate residue to a trust benefiting a foundation, but the trust lacked language needed for the intended charitable tax treatment. A court ordered a reformation after…
PLR 200425026: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425025: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425024: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425023: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425022: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425021: Foreign entity may file late partnership classification election
The members of a foreign entity intended it to be classified as a partnership for U.S. federal tax purposes, but Form 8832 was inadvertently not filed. The IRS found that the entity met the…
PLR 200425020: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425019: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425018: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425017: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425016: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425015: Foreign subsidiary may elect disregarded entity status late
A foreign entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was filed late. The IRS found that the requirements…
PLR 200425014: Subsidiary may elect disregarded entity status late
An entity wholly owned by another company intended to elect treatment as a disregarded entity for U.S. federal tax purposes, but Form 8832 was not filed on time. The IRS found that the requirements…
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.