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 200125078: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
PLR 200125077: Grandchildren's trust divisions preserve GST exemption
Trustees proposed to partition four family trusts into separate trusts for each living grandchild, while preserving shares for any children born or adopted later. The new trusts would remain…
PLR 200125076: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
PLR 200125075: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
PLR 200125074: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
CCA 200125073: Replacing unchanged installment notes does not trigger gain
A parent corporation replaced installment notes held by its subsidiaries with new notes on the same terms, then redeemed notes held by outside shareholders. Chief Counsel advised that issuing the…
PLR 200125072: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
PLR 200125071: Extra time to elect partnership classification
A foreign private limited company intended to elect partnership treatment for federal tax purposes from its formation date but missed the Form 8832 deadline. It represented that it had at least two…
PLR 200125070: Dividing four family trusts preserves GST tax exemption
Trustees proposed to divide four trusts into separate trusts for each living grandchild to allow different investment strategies. Each new trust would receive a proportional share of the assets and…
PLR 200125069: Extra time granted for a section 338(h)(10) election
A foreign corporate purchaser and the sellers missed the deadline to elect deemed asset sale treatment for one acquired S corporation. The purchaser and sellers said they had relied on tax…
PLR 200125068: Extra time granted for a section 338(h)(10) election
A foreign corporate purchaser and the sellers missed the deadline to elect deemed asset sale treatment for one acquired S corporation. The purchaser and sellers said they had relied on tax…
PLR 200125067: Nuclear plant sale receives mixed decommissioning tax rulings
Several utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. In a ruling requested by one of the sellers, the IRS allowed the sellers' qualified funds to…
PLR 200125066: Nuclear plant sale receives mixed decommissioning tax rulings
Four sellers in one consolidated group and other utilities planned to sell a nuclear plant and transfer their decommissioning funds to the buyer. The IRS allowed the sellers' qualified funds to…
PLR 200125065: Partnership receives extra time for section 754 election
A partnership filed a return for a short tax year after one partner sold its interest to another, but omitted an election to adjust the basis of partnership property under section 754. The IRS found…
PLR 200125064: Extra time to elect corporate classification
A domestic corporation converted into a state limited partnership and intended to retain corporate treatment for federal tax purposes from the conversion date. The partnership missed the deadline to…
PLR 200125063: Parent gets more time for section 338(g) election
A parent corporation and its foreign subsidiary acquired all the stock of a foreign target but did not file a valid section 338(g) election by the deadline. The parent said a tax professional had…
PLR 200125062: Late S corporation election receives relief
A newly incorporated company intended to elect S corporation status from its first tax year but missed the election deadline. The IRS found reasonable cause for the late filing. It agreed to…
PLR 200125061: Inadvertently invalid S election receives relief
A corporation's charter gave certain shares dividend and liquidation preferences when it elected S corporation status. Those rights meant it had more than one class of stock and its election was…
CCA 200125060: Unclear refund recipient after parent agency is broken
An insolvent subsidiary's receiver sought refunds for a consolidated corporate group after the IRS ended the common parent's authority to act for that subsidiary. Chief Counsel explained that a…
PLR 200125059: Former resident's departure was not for tax avoidance
A former US lawful permanent resident sought a ruling under the expatriation rules in force at the time. His net worth exceeded the threshold that could create a presumption that he left to avoid US…
PLR 200125058: Foreign entity gets more time for disregarded status election
A foreign entity and its owner intended from formation to treat the entity as disregarded for US tax purposes but did not file Form 8832 on time. The owner initially held the entity directly, then…
PLR 200125057: Late S corporation election allowed after adviser missed filing
A corporation's sole shareholder relied on an outside adviser to file Form 2553 for S corporation status, but the form was not filed on time. The IRS found reasonable cause for the missed deadline.…
PLR 200125056: Extra time for closing-of-the-books election
A consolidated group missed the deadline to elect a closing-of-the-books allocation for its ownership change year after a buyer acquired its parent. That election would allocate income and losses…
PLR 200125055: Business split qualifies for tax-free stock distribution
A corporation planned to separate two operating businesses by distributing all the stock of its subsidiary to a shareholder who would surrender her shares in the parent. Before the exchange, the…
PLR 200125054: Missing Form 2553 allowed after S corporation filings
A corporation intended to be an S corporation from its first tax year but never filed Form 2553. It had filed an S corporation return, and its shareholders had filed individual returns consistently…
PLR 200125053: Master-feeder fund receives partnership and RIC rulings
Two investment funds planned to contribute cash and diversified securities to a master trust treated as a partnership. The IRS concluded that the trust would not be a publicly traded partnership,…
PLR 200125052: Revised nuclear decommissioning funding schedule approved
An electric utility asked the IRS to revise the annual funding amounts for its qualified nuclear decommissioning fund. The utility supplied updated cost estimates, rates, and allocations among three…
PLR 200125051: Expatriation presumption rebutted, motive left undecided
A former US long-term resident asked for a ruling under the expatriation rules then in force after giving up permanent resident status. His net worth exceeded the threshold that could create a…
PLR 200125050: Parent gets more time for foreign target section 338 election
A domestic subsidiary bought all the stock of a foreign target, but its consolidated group's parent missed the deadline to make a section 338(g) election. The parent said it had reasonably relied on…
PLR 200125049: Revised nuclear decommissioning funding schedule approved
An electric utility asked the IRS to revise the annual funding amounts for its qualified nuclear decommissioning fund. The utility supplied updated cost estimates, rates, and allocations among three…
PLR 200125048: Late S corporation election effective from incorporation
A corporation's shareholder wanted S corporation status from the date of incorporation, but the election was not filed on time. The IRS found reasonable cause for the missed deadline. It concluded…
PLR 200125047: Late S corporation election effective from start of business
A corporation's shareholder wanted S corporation status from the date it began doing business, but the election was not filed on time. The IRS found reasonable cause for the missed deadline. It…
PLR 200125046: Corporate resolution supports late S election relief
Two shareholders intended their newly incorporated company to be an S corporation for its first tax year, but Form 2553 was not filed on time. An officers' resolution from that year recorded the…
PLR 200125045: Missed trust election gets inadvertent S termination relief
A trust acquired shares in an S corporation, but its sole beneficiary inadvertently failed to make the election needed for the trust to be an eligible shareholder. The IRS found that the…
PLR 200125044: Asset transfer and public spin-off receive nonrecognition rulings
A publicly traded corporation transferred one business's assets to a controlled company, which sold a minority stake in a public offering, and planned to distribute its remaining stock to…
PLR 200125043: Mutual insurer merger receives reserve and policy tax rulings
Two mutual life insurers planned a statutory merger, followed by transfer of a business segment to a subsidiary through coinsurance and related asset transfers. Assuming the merger qualified as a…
PLR 200125042: Late S corporation election effective from incorporation
A corporation's shareholder wanted S corporation status from the date of incorporation, but the election was not filed on time. The IRS found reasonable cause for the missed deadline. It concluded…
PLR 200125041: Late S election allowed from requested effective date
A corporation's shareholder intended S corporation treatment from a specified date, but the company did not file its election on time. The IRS found reasonable cause for the missed deadline. It said…
PLR 200125040: Trust severance and late reverse QTIP election allowed
An estate made a QTIP election for a trust but omitted the reverse QTIP election used for generation-skipping transfer tax purposes. It proposed to divide the trust into two, with one funded in an…
PLR 200125039: Bankruptcy-related section 338 election receives extra time
A purchaser and the selling group's parent missed the deadline for a section 338(h)(10) election after the purchaser acquired a subsidiary's stock. The purchaser and target later entered bankruptcy…
PLR 200125038: Corporate trustee appointment preserves trust tax treatment
A family planned to replace the trustees of several irrevocable trusts with a trust company partly owned through family interests. The company had rules barring officers and directors from taking…
PLR 200125037: Property transfer and resale rights preserve trust's GST exemption
An irrevocable trust owned commercial real estate and all the shares of a corporation. Its trustee proposed to transfer the real estate to a limited liability company owned by the trust and add…
PLR 200125036: Partnership receives more time to elect corporate tax treatment
A limited partnership formed from a predecessor S corporation intended to elect taxation as a corporation but missed the deadline to file Form 8832. The IRS granted it 60 days from the ruling letter…
PLR 200125035: Partnership receives more time to elect corporate tax treatment
A limited partnership formed from a predecessor S corporation intended to elect taxation as a corporation but missed the deadline to file Form 8832. The IRS granted it 60 days from the ruling letter…
PLR 200125034: Partnership receives more time to elect corporate tax treatment
A limited partnership formed from a predecessor S corporation intended to elect taxation as a corporation but missed the deadline to file Form 8832. The IRS granted it 60 days from the ruling letter…
PLR 200125033: IRS withdraws earlier farm trailer excise tax ruling
The IRS told a taxpayer that it was reconsidering whether certain semitrailer bodies qualify for the federal excise tax exception for equipment designed to transport and unload feed, seed, or…
PLR 200125032: Foreign company gets more time to elect partnership treatment
A foreign joint-stock company and its owner intended for the company to be treated as a partnership for U.S. federal tax purposes after an ownership change. They did not file Form 8832 on time. The…
CCA 200125031: Former group parent signs tax assessment extensions after restructuring
A corporate group changed its structure through transactions in which another company became the common parent of its consolidated tax group. IRS Chief Counsel advised that the former common parent…
PLR 200125030: Foreign bank's transferred assets retain U.S. tax connections
A foreign bank closed its regulated U.S. banking branch and moved loans, securities, hedging swaps, and related contracts to its home office. Based on the bank's representations about its continuing…
PLR 200125029: Company receives relief for a late S corporation election
A corporation and its shareholders intended to elect S corporation status from the company's first tax year, and the company filed an S corporation return. The election itself was late. The IRS…
PLR 200125028: Single-member company gets more time to elect corporate classification
The owner of a single-member company intended it to be taxed as a C corporation, but did not know that Form 8832 was required within the ordinary filing window. The form was not filed. Applying the…
PLR 200125027: Company may make late S corporation election for its first year
The sole shareholder of a corporation intended S corporation treatment for its first tax year. A company resolution recorded that intent, but the company missed the deadline for Form 2553. The IRS…
PLR 200125026: Company may make late S corporation election for its first year
A corporation intended S corporation treatment from its formation. Minutes of its organizational meeting recorded that intent, but it missed the deadline for Form 2553. The IRS found reasonable…
PLR 200125025: Company may make late S corporation election for its first year
A corporation intended S corporation treatment from its formation. Its sole shareholder signed and completed Form 2553 on time, but the company did not file it by the deadline. The IRS found…
PLR 200125024: Company may make late S corporation election for its first year
A corporation intended S corporation treatment from its formation. It filed an S corporation return for that year but missed the deadline for Form 2553. The IRS found reasonable cause for the late…
PLR 200125023: Corporation receives relief for an unfiled S election
A corporation with two shareholders intended S corporation treatment from its formation but learned that its Form 2553 had not been filed on time. The IRS found reasonable cause under section…
PLR 200125022: Late S election accepted with filing and return conditions
A one-shareholder corporation intended S corporation status from its formation but learned that its election had not been filed on time. The IRS found reasonable cause under section 1362(b)(5) and…
CCA 200125021: Military product sales to agency do not qualify as FSC foreign trading receipts
A domestic corporation sold a military product to a U.S. government agency through a foreign sales corporation. The corporation argued that receipts from several contracts qualified for the FSC…
PLR 200125020: Business split-off qualifies for tax-free reorganization treatment
A public corporation planned to separate one of its two active businesses into a new controlled company. After transferring that business and related liabilities, the new company sold some shares in…
CCA 200125019: Footwear design costs need activity-by-activity research review
An athletic footwear company claimed all costs of its design and prototype department as research expenditures under section 174. Chief Counsel advised that costs qualify only when tied to work…
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.