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 200425013: Foreign entity may make a late partnership classification election
A foreign entity's members intended to elect partnership treatment for U.S. federal tax purposes, but Form 8832 was not filed. The IRS concluded that the entity qualified for discretionary relief to…
PLR 200425012: Foreign entity may make a late partnership classification election
A foreign entity's members intended to elect partnership treatment for U.S. federal tax purposes, but Form 8832 was not filed. The IRS concluded that the entity qualified for discretionary relief to…
PLR 200425011: Three foreign entities may file late classification elections
Three foreign entities in a tiered ownership structure intended to file entity classification elections effective on the same date, but each missed the Form 8832 filing. The IRS found that each…
PLR 200425010: Three foreign entities may file late classification elections
Three foreign entities in a tiered ownership structure intended to file entity classification elections effective on the same date, but each missed the Form 8832 filing. The IRS found that each…
PLR 200425009: Three foreign entities may file late classification elections
Three foreign entities in a tiered ownership structure intended to file entity classification elections effective on the same date, but each missed the Form 8832 filing. The IRS found that each…
PLR 200425008: Foreign entity may make a late partnership classification election
A foreign entity's members intended to elect partnership treatment for U.S. federal tax purposes, but Form 8832 was not filed. The IRS concluded that the entity qualified for discretionary relief to…
PLR 200425007: Two subsidiaries and a jointly owned entity may file late elections
Two foreign subsidiaries and an entity they jointly own intended to file entity classification elections, but each missed the Form 8832 filing. The IRS gave the two subsidiaries 60 days to elect…
PLR 200425006: Two subsidiaries and a jointly owned entity may file late elections
Two foreign subsidiaries and an entity they jointly own intended to file entity classification elections, but each missed the Form 8832 filing. The IRS gave the two subsidiaries 60 days to elect…
PLR 200425005: Two subsidiaries and a jointly owned entity may file late elections
Two foreign subsidiaries and an entity they jointly own intended to file entity classification elections, but each missed the Form 8832 filing. The IRS gave the two subsidiaries 60 days to elect…
PLR 200425004: Late partnership election allowed subject to tax return conditions
A foreign entity owned by two individuals intended to elect partnership treatment when it established a U.S. limited liability company, but missed the election deadline. The IRS granted 60 days to…
PLR 200425003: Closing agreement governs a merchant marine fund transfer
A corporate group proposed to move deposits in its merchant marine capital construction fund from one subsidiary to another in exchange for stock and assumption of liabilities. The IRS agreed that…
PLR 200425002: Estate may allocate GST exemption late to two trusts
A decedent created two trusts for her children and their descendants. Her accountant reported the transfers on a timely gift tax return but failed to allocate her generation skipping transfer tax…
PLR 200425001: Parent gets time to request a consolidation waiver
Two domestic subsidiaries left a parent's consolidated tax group after their shares were mistakenly placed under a foreign subsidiary. They later rejoined, but the parent missed the deadline to…
PLR 200424011: Surviving spouse may roll trust distributed Roth IRA into her own
A deceased Roth IRA owner's trust was named as beneficiary, and his surviving spouse planned to allocate the IRA to a revocable subtrust she controlled before distributing it to herself. The IRS…
PLR 200424010: IRA rollover deadline waived for funds held as cashier checks
A taxpayer withdrew money from a traditional IRA, used some for personal expenses and a required minimum distribution, and put the remaining funds into two cashier checks. Stress and confusion…
PLR 200424009: Late rollover allowed for an uncashed plan check
A former employer's retirement plan issued a check payable to the taxpayer's new employer plan but mailed it to the taxpayer. The taxpayer delayed giving the uncashed check to the new plan because…
PLR 200424008: Late plan rollover allowed after form errors and hurricane disruption
A retirement plan participant tried to arrange a direct rollover to an annuity contract, but an obsolete form and then an incorrectly completed replacement led the plan administrator to send her a…
PLR 200424007: Spouse may roll late plan distribution into her IRA
A retirement plan administrator moved a deceased participant's plan assets into a taxable account for his surviving spouse without telling her about a possible IRA rollover. Although a trust was the…
PLR 200424006: Advisor's wrong account form permits late IRA rollover
A taxpayer asked a financial advisor to roll a distribution from a former employer's retirement plan into an IRA. The advisor used a regular brokerage account application instead, so the funds were…
PLR 200424005: Surviving spouse receives late rollover relief for plan distributions
A surviving spouse received a check and a stock certificate from her late husband's retirement plan. She placed the check in a savings account before contributing the funds to an IRA, and she held…
TAM 200424004: Audit request bars automatic change of employer contribution deductions
A corporate group had deducted certain employer retirement plan contributions in a year before the related employee compensation was earned. During an audit, an IRS agent sent an information request…
TAM 200424003: Split bond refunding treated as one issue and taxable advance refunding
A political subdivision issued two series of bonds to advance refund earlier bonds and said the structure better matched debt payments with its revenues. The IRS concluded that the two series should…
TAM 200424002: Sports franchise media rights classified as Class IV assets
A partnership acquired a professional sports franchise and allocated its purchase price among the franchise's assets. An earlier IRS advice memorandum had treated its national and local broadcast…
TAM 200424001: Railroad track exchanges and replacement cost allocation
A railroad exchanged property for track components and used a convention that assigned the replacement components first to capital projects. The IRS advised that installed track treated as real…
PLR 200423042: Two IRA owners receive relief after unidentified distribution checks
Two IRA owners held both retirement and other investment accounts at the same firm. When they asked the firm to sell investments and send the proceeds, its checks did not identify which accounts the…
PLR 200423041: County may pick up employee pension contributions
A county adopted a retirement plan for certain public safety employees and resolved to pay their required contributions through a reduction in current salary. Employees could not choose cash instead…
PLR 200423040: City pension contribution pickup approved for employees with irrevocable elections
A municipal employer proposed to pay required pension contributions for certain police employees by reducing their cash salaries. Its resolution said the employees could not take those amounts in…
PLR 200423039: Late IRA rollover allowed after failed redeposit attempt
A taxpayer withdrew money from her IRA and later learned from her tax preparer that she should redeposit it. She tried to do so, but the IRA company refused because the 60 day deadline had passed.…
PLR 200423038: IRA rollover waiver denied after funds used to buy home site
A taxpayer withdrew money from an IRA to buy land for a personal residence. The taxpayer planned to replace the money with proceeds from the sale of a real estate investment, but that sale was…
PLR 200423037: IRA rollover deadline waived after son surrendered former spouse's annuity
A divorce order transferred an IRA annuity to a former spouse. Her son believed it still belonged to his father and arranged for it to be surrendered. The former spouse signed the request without…
PLR 200423036: Rollover deadline waived during husband's terminal illness
A former employee took a distribution from her employer's 401(k) plan and intended to roll it into an IRA. She missed the 60 day deadline while coping with her husband's terminal illness, extensive…
PLR 200423035: Rollover deadline waived after workers' compensation delay
A worker with a partial disability took a distribution from an employer retirement plan while waiting for a workers' compensation claim to be settled. The worker intended to replace the money after…
PLR 200423034: City pension contributions treated as employer contributions
A city adopted a resolution to pay mandatory contributions to its governmental defined benefit plan on behalf of a group of employees. The employees could not take the contribution amounts as cash.…
PLR 200423033: IRA redeposit timely after first home purchase fell through
A first time homebuyer withdrew money from an IRA to buy a home, but the seller rejected the offer. The taxpayer returned the money to the IRA about 72 days after withdrawing it and asked the IRS to…
PLR 200423032: IRA rollover deadline waived after broker failed to open account
A taxpayer intended to move IRA funds to a new IRA at a brokerage firm and use that account to buy shares in an initial public offering. The broker failed to supply the paperwork needed to establish…
PLR 200423031: Late plan rollover accepted after deadline misunderstanding
A former employee moved part of a distribution from one qualified employer plan into another about 86 days after receiving it. He believed the rollover deadline was 90 days because an earlier…
PLR 200423030: Couple receives time to reverse ineligible Roth IRA conversions
A married couple converted traditional IRAs to Roth IRAs for 1998 on their tax adviser's recommendation. Their income exceeded the $100,000 limit for those conversions, but conflicting and…
PLR 200423029: Investment pool for charitable remainder trusts avoids self-dealing
A private foundation served as trustee and charitable beneficiary of ten charitable remainder unitrusts. It proposed an LLC, taxed as a partnership, to pool the trusts' cash for investing. The IRS…
CCA 200423028: Lottery payment trust issued seller notes and received withholding credits
Two lottery winners agreed to sell rights to their remaining prize payments, and a trust ultimately acquired those rights and issued installment notes to the winners. Chief Counsel advised that the…
CCA 200423027: Consolidated group cannot deduct the same economic loss twice
Chief Counsel addressed a consolidated group's potential deductions when a subsidiary's asset and the subsidiary's stock reflect the same economic loss. It advised that the group cannot take both…
CCA 200423026: Seizure notice dates cannot be disclosed to a buyer after sale
A buyer of real estate sold by the IRS wanted the dates of the notices of seizure and sale to complete a later sale. Chief Counsel advised that section 6103(k)(6) can allow disclosure of those dates…
PLR 200423025: Structured settlement transfers to affiliate qualify for nonrecognition
A corporate group planned to sell two subsidiaries while moving their structured settlement contracts and related liabilities to another group corporation as payees consented. The IRS ruled that the…
PLR 200423024: Structured settlement transfers to affiliate qualify for nonrecognition
A corporate group planned to sell two subsidiaries while moving their structured settlement contracts and related liabilities to another group corporation as payees consented. The IRS ruled that the…
PLR 200423023: Subsidiary receives more time to elect corporate tax status
A wholly owned subsidiary intended to elect corporate classification for federal tax purposes but missed the filing deadline. The IRS found that the requirements for discretionary relief under…
PLR 200423022: Corporation receives relief for late S election
A corporation's shareholder intended S corporation treatment from a specified date, but the election was filed late. The IRS found reasonable cause for the missed deadline and granted relief under…
PLR 200423021: Trust eligibility lapse receives inadvertent S election relief
Four trusts held stock in an S corporation. They stopped qualifying as eligible shareholders when their beneficiaries ceased to be treated as owners of the entire trusts, which terminated the…
PLR 200423020: Federally assisted housing building receives 10-year rule waiver
A limited partnership acquired a building serving elderly and disabled residents and planned to claim low-income housing tax credits for its acquisition and rehabilitation. An existing building…
PLR 200423019: Foreign entity receives more time to elect partnership status
A foreign entity with two owners began business but missed the deadline to elect partnership classification for U.S. federal tax purposes. The IRS found that the requirements for discretionary…
PLR 200423018: Late notarized statements satisfy ESOP sale filing rule
Taxpayers sold company stock to an employee stock ownership plan and bought replacement securities while seeking gain deferral under section 1042. They missed the rule requiring a notarized…
PLR 200423017: Missed trust election receives inadvertent S termination relief
A trust acquired shares of an S corporation, but its beneficiary failed to elect qualified subchapter S trust treatment. The IRS concluded that the acquisition terminated the corporation's S…
PLR 200423016: Transfer to disregarded LLC preserves subscription income deferral
A newsletter publisher elected under section 455 to report prepaid subscriptions over the periods it had to deliver the publications. It planned to move some newsletters and the related subscription…
TAM 200423015: Trader's late filing fails to elect mark-to-market accounting
A securities trader wanted to use mark-to-market accounting under section 475(f) for a tax year and filed Form 3115 with an election statement. The statement arrived after the deadline set by…
TAM 200423014: Cash accounting rule cannot reverse earlier accrual method change
During an examination, the IRS required a glazing company to change from cash to accrual accounting because it determined the company needed to account for inventories. The company and its…
PLR 200423013: Former QSub receives relief for missed S election
An S corporation distributed a subsidiary's stock to its shareholders, ending the subsidiary's qualified subchapter S subsidiary election. The parties intended the subsidiary to become an S…
PLR 200423012: Former affiliated-company secretary qualifies as outside director
A director of a surviving corporation had previously served as secretary and board member of a related corporation that merged into it. The director received no payment from the surviving…
PLR 200423011: Foreign entity receives time to elect disregarded status
A foreign entity intended to be disregarded for U.S. federal tax purposes from its formation date, but inadvertently missed the deadline to file Form 8832. It represented that it was eligible to…
PLR 200423010: Foreign entity receives time to elect disregarded status
A foreign entity intended to be disregarded for U.S. federal tax purposes from a specified date, but inadvertently missed the deadline to file Form 8832. It represented that it was eligible to make…
PLR 200423009: Foreign entity receives time to elect disregarded status
A foreign entity intended to be disregarded for U.S. federal tax purposes from a specified date, but inadvertently missed the deadline to file Form 8832. It represented that it was eligible to make…
PLR 200423008: Foreign entity receives time to elect disregarded status
A foreign entity intended to be disregarded for U.S. federal tax purposes from a specified date, but inadvertently missed the deadline to file Form 8832. It represented that it was eligible to make…
PLR 200423007: Extension granted for dual consolidated loss certifications
A taxpayer omitted annual certifications for dual consolidated losses of three foreign hybrid entity separate units from a federal tax return. Its accounting firm later discovered the omission and…
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.