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 200252049: Company receives relief for inadvertent S election termination
Two trusts holding stock in an S corporation failed to distribute all their income to their beneficiaries for several years. That failure caused the corporation's S election to terminate because the…
PLR 200252048: Company receives relief for inadvertent S election termination
Two trusts holding stock in an S corporation failed to distribute all their income to their beneficiaries for several years. That failure caused the corporation's S election to terminate because the…
PLR 200252047: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for a taxable year. That failure caused the corporation's S election to terminate…
PLR 200252046: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for two taxable years. That failure caused the corporation's S election to…
PLR 200252045: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for three taxable years. That failure caused the corporation's S election to…
PLR 200252044: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for four taxable years. That failure caused the corporation's S election to…
PLR 200252043: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for one taxable year. That failure caused the corporation's S election to…
PLR 200252042: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for one taxable year. That failure caused the corporation's S election to…
PLR 200252041: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for four taxable years. That failure caused the corporation's S election to…
PLR 200252040: Company receives relief for inadvertent S election termination
Two trusts became shareholders of an S corporation but failed to distribute all their income to their beneficiaries for four taxable years. That failure caused the corporation's S election to…
PLR 200252039: IRS restores an S corporation election after trust distribution failures
A corporation's S corporation election terminated because two shareholder trusts did not distribute all of their income to their current beneficiaries. The IRS treated the termination as inadvertent…
PLR 200252038: S corporation status continues after shareholder trusts miss income distributions
Two shareholder trusts failed to distribute all of their income to their beneficiaries for a tax year, causing the corporation's S election to terminate. After discovering the problem, the trustees…
PLR 200252037: Commercial property rents are excluded from S corporation passive investment income
A corporation with accumulated earnings and profits planned to elect S corporation status and asked whether rent from its commercial properties counted as passive investment income. It described…
PLR 200252036: Shopping center rents are excluded from S corporation passive investment income
A corporation planning to elect S status asked whether rents from shopping centers it owned and managed would count as passive investment income. Its employees and contractors inspected and…
PLR 200252035: Business trust gets more time to elect corporate tax classification
A business trust intended to be taxed as a corporation but inadvertently failed to file Form 8832. It asked for more time to make the entity classification election under Treas. Reg. § 301.7701-3.…
PLR 200252034: Entity receives relief for late corporate classification and S elections
An entity intended to elect corporate tax classification and S corporation status from its formation date, but neither election was timely filed. The IRS granted 60 days from the letter date to file…
PLR 200252033: State dissolution does not require a new S corporation election
A state administratively dissolved a corporation for failing to file a required report. The corporation did not know of the dissolution, kept filing S corporation returns, and later reincorporated.…
TAM 200252032: Foreign foundation gifts qualify for estate, gift, and estate income tax deductions
A U.S. decedent created a foundation abroad, gave it funds during life, and left it the estate residue. The estate examiner had disallowed the charitable estate tax deduction because the…
PLR 200252031: Sole shareholder's corporation receives late S election relief
A corporation's sole shareholder intended S corporation treatment from the incorporation date, but Form 2553 was not filed on time. The IRS found reasonable cause for the missed deadline under IRC §…
PLR 200252030: Corporation may file a late S election from its incorporation date
A corporation's president said the company had intended to elect S corporation treatment from its incorporation date, but Form 2553 was not filed on time. The IRS found reasonable cause for the…
TAM 200252029: Separated natural gas liquids do not qualify for the tight formation gas credit
A gas producer claimed the IRC § 29 credit on both dry gas and natural gas liquids from wells that included a designated tight formation. The liquids were separated at a gas plant before the…
TAM 200252028: Film depreciation forecast must subtract distribution costs
A film company calculated depreciation under an income forecast formula using film receipts before subtracting distribution costs. The IRS advised that this was an improper use of the income…
PLR 200252027: Cooperative asset sale gains can be allocated as patronage income
A wholesale cooperative planned to sell substantially all its assets and distribute proceeds to its members. It asked whether gain on assets used in its wholesale and distribution business could be…
PLR 200252026: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252025: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252024: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252023: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252022: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252021: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252020: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252019: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252018: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252017: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252016: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252015: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252014: Parent's restructuring into partnership form receives tax rulings
A parent corporation proposed restructuring its business by contributing assets and liabilities through subsidiaries to a newly formed partnership, distributing partnership and general partner…
PLR 200252013: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252012: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252011: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252010: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252009: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252008: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252007: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252006: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252005: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252004: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252003: Parent company receives a second extension to file a section 338 election
A corporate group missed both the original deadline and a prior extension for a § 338 election concerning a foreign target acquired through partnership interests. The IRS found reasonable reliance…
PLR 200252002: Foreign merger receives a section 367 exception for U.S. shareholders
A foreign corporation proposed to acquire a U.S. target through a merger, with U.S. shareholders exchanging target stock for shares and other securities of the foreign acquirer. The IRS ruled that…
PLR 200252001: Proposed municipal bonds avoid replacement proceeds and abusive arbitrage treatment
An issuer planned to refund certain capital appreciation bonds and issue later bonds to pay interest on the refunding bonds and previously issued subsequent bonds. The IRS ruled that the proposed…
PLR 200251023: Pension plan receives a conditional minimum funding waiver
The IRS granted a conditional waiver of the minimum funding standard for a company's defined benefit pension plan for the year ended December 31, 2001. The company had suffered repeated losses and…
PLR 200251022: Pension plan receives a minimum funding waiver for 2001
The IRS granted a waiver of the minimum funding standard for a company's defined benefit pension plan for the year ended December 31, 2001. The company had negative earnings in 1999 and 2000, had…
PLR 200251021: Pension plan receives a minimum funding waiver for 2001
The IRS granted a waiver of the minimum funding standard for a company's defined benefit pension plan for the year ended December 31, 2001. The company had negative earnings in 1999 and 2000, had…
PLR 200251020: Pension plan receives a conditional funding waiver for 2001
The IRS granted a conditional waiver of the minimum funding standard for a company's defined benefit pension plan for the year ended December 31, 2001. A new actuary had reported a much larger…
PLR 200251019: Religious materials and training costs qualify as foundation distributions
A private foundation asked how its religious outreach spending would be treated for federal tax purposes. It distributed free Bible recordings, cassette players, and printed materials to prison…
PLR 200251018: Foreign investment corporation shields trust from most unrelated business income
A charitable remainder unitrust held an interest in a partnership that planned to invest in funds through a foreign corporation. Some funds could borrow to buy investments, which raised a question…
PLR 200251017: Foreign investment corporation shields trust from most unrelated business income
A charitable remainder unitrust held an interest in a partnership that planned to invest in funds through a foreign corporation. Some funds could borrow to buy investments, which raised a question…
PLR 200251016: Foreign investment corporation shields trust from most unrelated business income
A charitable remainder unitrust held an interest in a partnership that planned to invest in funds through a foreign corporation. Some funds could borrow to buy investments, which raised a question…
PLR 200251015: College retirement and severance plans qualify as church plans
A religiously affiliated college asked whether two new employee benefit plans would qualify as church plans. One plan provided supplemental retirement benefits for certain tenured faculty, and the…
PLR 200251014: Late accounting-period application treated as timely
A taxpayer filed Form 1128 late while seeking to change its tax year from August 31 to December 31. The IRS found that the late filing resulted from an error or misunderstanding and that the…
CCA 200251013: Incorrect withholding form ID delays refund interest
Chief Counsel advised on a foreign partner's tax return that claimed credit for partnership withholding. The return showed the partner's correct taxpayer identification number, but its attached Form…
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.