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 200307041: Ditch company has no gain on shareholders water rights sales
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307040: Water rights transfers create no company gain or distribution
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307039: Water rights transfers produce no ditch company tax
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307038: Shareholders water rights transfers produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307037: Water rights sales do not create a corporate distribution
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307036: Water rights sales are not company property sales
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307035: Water rights transfers are attributable to selling shareholders
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307034: Water rights sales yield no gain to ditch company
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307033: Ditch company is untaxed on shareholders water rights sales
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307032: Water rights transfers belong to shareholders for tax purposes
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307031: Water rights transactions create no gain for ditch company
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307030: Shareholder water rights transfers leave company untaxed
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307029: Ditch company has no tax on members water rights transfers
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307028: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307027: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307026: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307025: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307024: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307023: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307022: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307021: Members water rights transfers do not create company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307020: Shareholder water rights sales cause no ditch company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307019: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307018: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307017: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307016: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307015: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307014: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307013: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307012: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307011: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307010: Shareholder water rights sales produce no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307009: Shareholder water rights transfers create no company gain
Shareholders planned to transfer water rights allocated through a mutual ditch company, which would only amend its allotment contract and receive no sale proceeds. The IRS ruled that the…
PLR 200307008: Corporation receives relief for late S election
A corporation's shareholders wanted S corporation treatment from its incorporation date, but its S election was not filed on time. The company sought relief under § 1362(b)(5). The IRS found…
PLR 200307007: Foreign subsidiary gets time for disregarded entity election
A domestic corporation wholly owned a foreign entity that intended to be treated as disregarded for U.S. tax purposes from its incorporation date. The foreign entity missed the deadline to file its…
PLR 200307006: Amended employee stock purchase plan qualifies under section 423
A company asked whether amendments to its employee stock purchase plan preserved its qualification under § 423. The plan offered eligible employees quarterly chances to buy company stock, with a…
PLR 200307005: Late corporate classification and S corporation elections allowed
A single-owner eligible entity intended to elect corporate tax classification and then S corporation status, both effective on the same redacted date, but missed both filing deadlines. The IRS…
PLR 200307004: Nonprofit bond issuer acts on behalf of the state
A nonprofit corporation formed by a state-controlled authority proposed to issue bonds for borrowers under a redacted Code provision. The governor had ultimate control of its board and would approve…
PLR 200307003: Complete expatriation submission removes tax avoidance presumption
A person who held U.S. citizenship and citizenship in the country where he had lived since birth asked about the tax consequences of renouncing his U.S. citizenship. He submitted information under §…
PLR 200307002: Acquired group may use tax book values to apportion interest expense
A domestic corporation acquired a group that had used fair market values to apportion interest expense, while the acquirer's group used tax book values. The acquirer asked to let the acquired group…
PLR 200307001: Minority shareholder's redemption treated as a stock sale
A minority shareholder of a closely held S corporation wanted the company to redeem some of his shares through its annual buyback plan. The IRS considered both his direct holdings and shares…
PLR 200306039: IRS denies pension plan's proposed accrued benefit reduction
A multiple employer defined benefit pension plan for local union officers and business agents sought approval to reduce accrued benefits if a court ordered termination and plan assets could not…
PLR 200306038: Multiemployer plan status and funding ruling depend on Labor Department finding
A pension plan originally sponsored by one company later included employees of a second, unrelated company under a separate union agreement. The plan asked whether it qualified as a multiemployer…
PLR 200306037: Former resident's submission removes tax avoidance presumption
A former U.S. long-term resident relinquished his green card and returned to the country where he was born and held citizenship. His net worth exceeded the threshold that would normally create a…
PLR 200306036: Former resident's expatriation lacked a principal tax avoidance purpose
A former U.S. long-term resident gave up his green card while living in the country where he was born and held citizenship. His net worth exceeded the threshold that would ordinarily create a…
PLR 200306035: Estate receives extra time for reverse QTIP election
An estate intended to make a reverse qualified terminable interest property (QTIP) election for a marital trust fund so the decedent's generation-skipping transfer (GST) exemption could apply to it.…
PLR 200306034: Corporation receives relief for late S election
A newly incorporated company and its three shareholders intended S corporation treatment from the date the company issued its stock, but the company missed the Form 2553 filing deadline. The IRS…
PLR 200306033: S corporation may spin off subsidiary business to its shareholders
An S corporation operating two businesses proposed to distribute all stock of its wholly owned subsidiary to its shareholders. The separation was intended to protect one business from the…
PLR 200306032: Late S election allowed with return filing condition
Two shareholders intended their new company to be an S corporation from its incorporation date, but the advisers they retained failed to file Form 2553. The IRS found reasonable cause for the missed…
PLR 200306031: Two taxpayers receive extra time to allocate GST exemptions
Two taxpayers transferred property to trusts for their children and later descendants, but their gift tax returns did not allocate generation-skipping transfer (GST) exemptions to transfers made in…
PLR 200306030: Late QSub election allowed after subsidiary acquisition
Two shareholders transferred all their shares in one S corporation to another S corporation they owned, making the first corporation a wholly owned subsidiary. The parent intended to elect qualified…
PLR 200306029: Inadvertent trust transfers do not end S corporation treatment
Shareholders transferred part of their S corporation stock to trusts that could not own S corporation shares, which terminated the company's S election. They said they had not known the transfers…
PLR 200306028: Adding a trustee preserves trust's GST grandfathered status
Trustees of an irrevocable trust funded before September 25, 1985 sought a court modification allowing three corporate executives to serve as co-trustees, instead of two, alongside another trustee.…
PLR 200306027: Additional co-trustee preserves trust's GST exemption
The trustees of an irrevocable trust established before September 25, 1985 sought a court order allowing three corporate executives, rather than two, to serve alongside another trustee. The trust…
PLR 200306026: Late S election accepted for corporation's first operating year
A corporation intended S corporation status from its first operating year, but did not seek professional help with the election and failed to file Form 2553. The IRS found reasonable cause for the…
PLR 200306025: Consolidated group may file late loss carryback waiver
The parent of a consolidated corporate group intended to waive the carryback period for a consolidated net operating loss, but a valid election was not filed with its return. The IRS found that the…
PLR 200306024: Company granted late S election relief from incorporation
A company's shareholders wanted S corporation treatment from its incorporation date, but the election was not filed on time. The IRS found reasonable cause for the missed filing under § 1362(b)(5).…
PLR 200306023: Group receives extra time for closing-of-the-books election
An acquisition changed ownership of a consolidated corporate group that had net operating losses. The parent wanted to allocate the change-year loss between the periods before and after the…
PLR 200306022: Corporation granted relief for missed S election deadline
Two shareholders decided their corporation should elect S status for a tax year beginning on a redacted date, but Form 2553 was not filed on time. The IRS found reasonable cause for the missed…
PLR 200306021: Sole shareholder's company receives late S election relief
The sole shareholder of a newly incorporated company intended S corporation treatment from its incorporation date, but the election was not filed on time. The IRS found reasonable cause under §…
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.