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 200241027: Synthetic fuel credit rulings reissued after interest sale
A buyer acquired an interest in a partnership that produced synthetic fuel from coal. The partnership also considered an alternative chemical reagent for its production process. The IRS found that…
PLR 200241026: First-year S corporation election receives filing relief
A company's sole shareholder intended to elect S corporation treatment for its first tax year, but the company did not timely file a completed Form 2553. The IRS found reasonable cause for the…
PLR 200241025: Revised nuclear decommissioning fund schedule approved
A utility that partly owned a nuclear plant requested a revised schedule governing deductible payments to its decommissioning fund. Two public utility commissions set the relevant rates and…
PLR 200241024: Late S corporation election allowed from incorporation
A corporation intended to be treated as an S corporation from its incorporation date, but it did not file the election on time. The IRS found that it had reasonable cause for the late filing and…
PLR 200241023: Commercial property rents are not passive investment income
An S corporation owned, leased, and managed commercial real estate where tenants operated facilities. It changed its leases from net leases and provided property maintenance, repairs, leasing,…
PLR 200241022: Taxpayer receives more time to allocate GST exemption to three trusts
A taxpayer and spouse transferred assets to an irrevocable trust divided into exempt and nonexempt trusts for their children and descendants. The taxpayer's accountant prepared the gift tax return…
PLR 200241021: Taxpayer receives more time to allocate GST exemption to three trusts
A taxpayer and spouse transferred assets to an irrevocable trust divided into exempt and nonexempt trusts for their children and descendants. The taxpayer's accountant prepared the gift tax return…
200241020: IRS pulled this release as a duplicate
The official IRS PDF contains only a notice marking this release as pulled because it was a duplicate. It provides no ruling text, issue date, legal analysis, or Code sections. The notice does not…
PLR 200241019: Synthetic fuel facility qualifies for section 29 credit on stated conditions
A partnership planned to buy and relocate a facility that converts coal into solid synthetic fuel. The IRS ruled that the facility's construction contract met the pre-1997 binding-contract…
PLR 200241018: Synthetic fuel facility qualifies for section 29 credit on stated conditions
A partnership planned to buy and relocate a facility that converts coal into solid synthetic fuel. The IRS ruled that the facility's construction contract met the pre-1997 binding-contract…
200241017: IRS pulled this release for an inspection delay
The official IRS PDF contains only a notice marking this release as pulled because of an inspection delay. It provides no ruling text, issue date, legal analysis, or Code sections. The notice does…
PLR 200241016: Equipment exchange program qualifies for gain deferral
An equipment leasing company proposed a program to exchange equipment leaving its lease portfolio for like-kind equipment entering new leases. The program used a qualified intermediary and escrow…
PLR 200241015: Late S corporation election allowed from incorporation
A corporation’s shareholders intended S corporation treatment from incorporation, but the election was not filed on time. The IRS found that it had reasonable cause for the late filing and granted…
CCA 200241014: Unsuccessful bid costs must be apportioned to awarded sales
A manufacturer incurred bid and proposal costs while competing for contracts to sell its products, including contracts that generated foreign trading gross receipts. It deducted costs for bids it…
PLR 200241013: Two vehicle exchanges qualify, but car for truck does not
A bank that leased vehicles proposed to exchange cars coming off lease for newly leased vehicles through a qualified intermediary. It asked whether an automobile could be exchanged for a passenger…
PLR 200241012: Marital trust and retirement benefits qualify for marital deduction
A decedent's revocable trust created a marital trust for a surviving spouse who was not a U.S. citizen. The trust had U.S. trustees, required withholding of tax on principal distributions, and…
PLR 200241011: Late S corporation election allowed from incorporation
A corporation’s sole shareholder intended S corporation treatment from incorporation, but the election was not filed on time. The IRS found that it had reasonable cause for the late filing and…
PLR 200241010: Planned green card surrender lacks tax-avoidance purpose
A long-term U.S. resident planned to surrender his green card and live in the country of his birth, where he was a citizen and subject to tax on worldwide income. His net worth exceeded the…
PLR 200241009: Additional partnership sale preserves synthetic fuel credit rulings
A buyer acquired an additional interest in a partnership that owned a coal-to-synthetic-fuel facility, and the partnership modified one production line. The IRS said the additional sale and related…
PLR 200241008: Sale of additional partnership interest preserves fuel credit rulings
Two sellers transferred an additional interest in a partnership that owned a coal-to-synthetic-fuel facility, and the partnership modified one production line. The IRS said the additional sale and…
PLR 200241007: Active building rents are not passive investment income
An S corporation owned and operated a building with residential units and retail stores. It and its contractors provided extensive maintenance, repairs, security, tenant services, leasing, and…
PLR 200241006: Active building rents are not passive investment income
An S corporation owned and operated a commercial building with retail stores. It and its contractors provided maintenance, repairs, security, tenant services, leasing, and management, and the…
PLR 200241005: Late S corporation election allowed for first tax year
A corporation intended to elect S corporation treatment from incorporation, as its employer identification number application indicated, but it did not timely file Form 2553. The IRS found…
PLR 200241004: Partnership receives time to elect corporate tax classification
A limited liability partnership intended to elect treatment as an association taxable as a corporation from its formation date and to join a consolidated group. The parties expected to file the…
PLR 200241003: Parent receives more time for QSub election
An S corporation formed a subsidiary to acquire the assets of an unrelated company. It intended to elect qualified subchapter S subsidiary (QSub) treatment from the subsidiary's formation date, but…
PLR 200241002: Managed commercial rents are not passive investment income
A corporation owned, leased, and managed commercial real estate through its shareholder and contractors. Its services included common-area cleaning, structural and system repairs, snow removal,…
PLR 200241001: Employee stock purchase plan qualifies under section 423
A company asked whether its amended employee stock purchase plan qualified under IRC § 423 and how participants would be taxed. The plan allowed eligible employees to buy shares through payroll…
PLR 200240054: Police pension contributions are treated as employer contributions
A public employer adopted a retirement plan for its certified police officers with mandatory employee contributions equal to seven percent of compensation. An ordinance required the employer to pay…
PLR 200240053: Staffing change leaves prior medical office ruling in effect
An entity that owned and leased medical office buildings asked the IRS to modify the facts stated in an earlier private letter ruling. The revised statement allowed part-time employees of another…
PLR 200240052: Blended investment option preserves 403(b) plan treatment
A state retirement system proposed a shared 403(b) plan for employees of public technical schools. One investment option combined group annuity contracts with custodial accounts holding stock of…
PLR 200240051: Mutual insurer conversion qualifies as recapitalization; retirement policy credits defer tax
A mutual life insurer planned to convert to a stock company, then merge with a subsidiary of another company. The IRS ruled that the conversion qualified as a recapitalization under § 368(a)(1)(E),…
PLR 200240050: Late S corporation election may be treated as timely
Two shareholders intended their corporation to elect S corporation status but did not file Form 2553 on time. They had consistently filed tax returns as though the corporation had made the election.…
PLR 200240049: Car exchanges for van and SUV qualify; car exchange for truck does not
A vehicle leasing company used a qualified intermediary to exchange cars coming off lease for newly leased vehicles. It asked whether three deferred exchanges qualified for nonrecognition under §…
PLR 200240048: LLC receives time to file corporate classification election
A multi-member LLC intended to be taxed as an S corporation and timely filed Form 2553, but inadvertently omitted Form 8832 to elect corporate classification. Without that classification, its…
CCA 200240047: Overpayment interest ends at due date of return credited
The IRS applied a corporation's overpayment for one year against an underpayment for the following year. Counsel advised that § 6611 overpayment interest ran from the date the overpayment arose to…
PLR 200240046: Extension granted to file dual consolidated loss agreements
A taxpayer failed to attach required agreements for an entity's dual consolidated losses to returns for four tax years. It sought relief before the IRS discovered the omissions and supplied…
PLR 200240045: Time extended for dual consolidated loss elections and certifications
A taxpayer reported losses from two foreign hybrid entity units on its U.S. returns but omitted the related dual consolidated loss elections and annual certifications. Its tax adviser supplied…
PLR 200240044: Missed trust election treated as inadvertent S corporation termination
After a shareholder died, a trust holding shares of an S corporation was divided into several trusts. A beneficiary failed to elect qualified subchapter S trust status for one trust, terminating the…
PLR 200240043: Oil partnership receipts retain their character for S corporation passive income test
An S corporation with accumulated earnings and profits planned to invest in publicly traded partnerships handling crude oil and petroleum products. It asked how its share of partnership receipts…
CCA 200240042: Worker classification petition did not suspend assessment deadline without notice
The IRS assessed employment taxes after deciding a worker was an employee, but it had not first mailed the required worker classification Notice of Determination. The taxpayer filed a Tax Court…
PLR 200240041: Former long-term resident's departure not treated as tax avoidance
A former U.S. long-term resident gave up his green card and became a tax resident of his country of birth. His net worth exceeded the threshold that could create a presumption of tax avoidance under…
PLR 200240040: New owners may elect S corporation status before five-year wait ends
A corporation's S election ended when an ineligible shareholder bought its stock. Three new shareholders later acquired all its shares and wanted to restore S corporation treatment before the…
PLR 200240039: Apartment rental income excluded from S corporation passive income test
An S corporation owned and operated a residential apartment building. It performed or arranged substantial maintenance, repairs, security, tenant services, lease administration, and emergency…
PLR 200240038: Immediate ESOP stock repurchase preserves S corporation election
An S corporation was wholly owned by its employee stock ownership trust. It planned to distribute company shares to some plan participants who elected direct rollovers to IRAs, while immediately…
CCA 200240037: Signed examination agreement bars liability challenge in levy appeal
A taxpayer signed an examination form consenting to immediate assessment and giving up administrative and Tax Court appeals of additional income tax. After the IRS proposed a levy, he tried to…
PLR 200240036: Gas production payment treated as loan, preserving fuel credits
An owner of oil and gas working interests planned to sell another party a right to payments from a limited amount of future gas production. The right was payable only from the burdened properties…
PLR 200240035: Late S corporation election granted conditional relief
A corporation intended to be taxed as an S corporation but did not file Form 2553 on time. The IRS found reasonable cause for the missed deadline under § 1362(b)(5). It ruled that an election…
PLR 200240034: Commercial property rents excluded from S corporation passive income test
An S corporation with accumulated earnings and profits owned and managed commercial property. Through contractors and rental agents, it provided maintenance, repairs, emergency service, security…
PLR 200240033: Apartment rental income excluded from S corporation passive income test
An S corporation owned and operated a residential apartment building. It performed or arranged substantial maintenance, repairs, security, tenant services, lease administration, and emergency…
PLR 200240032: Actively managed commercial rents excluded from S corporation passive income test
A C corporation planning to elect S status owned a commercial building with retail tenants. It provided or arranged maintenance, repairs, security, leasing administration, and around-the-clock…
PLR 200240031: Late S corporation election allowed after accountant missed filing
A corporation's president and shareholder relied on an accountant to file an S corporation election effective from incorporation, but Form 2553 was not filed on time. The IRS found reasonable cause…
PLR 200240030: Late GST exemption allocation allowed at original gift value
A taxpayer created and funded a family trust intending to allocate generation-skipping transfer tax exemption to it. A miscommunication between legal and accounting advisers left the allocation off…
PLR 200240029: Late GST exemption allocation allowed at original gift value
A taxpayer agreed to split her spouse’s gift to a family trust and intended to allocate her generation-skipping transfer tax exemption. A miscommunication between legal and accounting advisers left…
PLR 200240028: Cities' power grid access agreement is not deliberate private bond use
A public power agency had bonds financing transmission facilities used by member cities. Several cities planned to transfer operational control of their transmission entitlements to an independent…
PLR 200240027: Charitable lead trusts qualify for gift deduction; grantor status partly unresolved
Two spouses funded three irrevocable charitable lead unitrusts that would pay six percent of their annually valued assets to charity for 20 years, then benefit their children. The IRS allowed a gift…
PLR 200240026: Apartment rental income excluded from S corporation passive income test
An S corporation owned and operated a residential apartment building. It performed or arranged substantial maintenance, repairs, security, tenant services, lease administration, and emergency…
PLR 200240025: Late S corporation election may apply from first tax year
The shareholders of a newly incorporated company intended it to be an S corporation from its first tax year, but no timely Form 2553 was filed. The IRS found reasonable cause for the missed deadline…
CCA 200240024: Third-party tax records in lease-stripping litigation require a direct link
A partnership's tax case concerned the basis of preferred stock traceable to lease-stripping transactions involving other taxpayers. IRS Counsel addressed which records from those taxpayers'…
200240023: IRS pulled this release for an inspection delay
The official IRS PDF contains only a notice marking this release as pulled because of an inspection delay. It provides no ruling text, issue date, legal analysis, or Code sections. The notice does…
PLR 200240022: Funds receive time to make and increase consent dividend elections
Two regulated investment companies discovered that they had understated interest income from securities, including zero coupon investments. One fund had omitted a consent dividend election, and 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.