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 200121074: Conditional pension funding waiver granted
The IRS granted a conditional waiver of the minimum funding standard for a defined benefit pension plan's year ending July 31, 2000. The employer had contributed 59% of the required amount but said…
PLR 200121073: Surviving spouse may roll over her share of divided IRAs
An IRA owner died before reaching age 70½, leaving 45% of his IRA to his spouse and the rest to two other beneficiaries. The IRA was split into two accounts, each containing a separately tracked…
PLR 200121072: Retirement plan policy credits in an insurer demutualization
A mutual life insurer planned to convert to a stock company and give policy credits to holders of certain annuities and retirement plan contracts in place of stock or cash. The IRS ruled that adding…
CCA 200121071: Section 482 allocation in a lease stripping transaction
Chief Counsel considered a lease stripping transaction in which a partnership transferred stock with a claimed high tax basis and low market value to a corporation, which then sold the stock and…
CCA 200121070: Employee cannot deduct expenses from renting home space to employer
An employee who owned an S corporation rented part of his home to the corporation and used that space to perform his work. Chief Counsel advised that IRC § 280A(c)(6) bars his deductions for…
PLR 200121069: Supplemental rulings for a corporate separation
A corporation asked the IRS to supplement an earlier ruling on separating two businesses under IRC § 355 after market changes and related transaction changes. The controlled company's active…
PLR 200121068: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121067: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121066: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121065: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121064: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121063: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121062: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121061: Business separation to resolve shareholder management disputes
Five owners of an S corporation disagreed about how to run their business. The corporation proposed transferring part of its assets and liabilities to a new corporation, then giving all of the new…
PLR 200121060: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121059: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121058: Partnership receives more time to elect a basis adjustment
A limited partnership missed the deadline to elect basis adjustments under IRC § 754 after an ownership interest changed hands. Its tax return preparer did not discuss the election or include it…
PLR 200121057: Corporation receives relief for a late S election
A corporation's shareholders intended to elect S corporation status when the company was formed, and the company filed an S corporation tax return. Its Form 2553 election was never filed with the…
PLR 200121056: Shareholder resolution supports a late S election
A newly formed corporation's shareholders intended it to be an S corporation, but its Form 2553 election was not filed on time. Their resolution stated that the company would elect S status, and a…
PLR 200121055: Trust owned corporation receives late S election relief
A trust held all shares of a corporation, and a person treated as the owner of those shares intended the company to elect S status. An officer resolution recorded that intent, but Form 2553 was not…
PLR 200121054: Mutual bank conversion receives four subissue rulings
A mutual savings bank planned to convert to a stock bank within a mutual holding company structure. Its depositors would exchange their mutual interests for stock and then for mutual interests in…
PLR 200121053: LLC receives more time to elect corporate tax status
A two member limited liability company wanted to be taxed as a corporation from the start of its first tax year. It missed the deadline to file Form 8832 with that effective date, so the default…
PLR 200121052: Late S corporation election allowed for first tax year
A corporation and its sole shareholder intended S corporation treatment from the company's first tax year. The company filed an S corporation income tax return but did not file the required Form…
PLR 200121051: Late S corporation election allowed for first tax year
A corporation and its sole shareholder intended S corporation treatment from the company's first tax year. The company filed an S corporation income tax return but did not file the required Form…
PLR 200121050: Partnership receives more time to make a basis adjustment election
A partnership filed its return without an IRC § 754 election after a partner died. That election allows basis adjustments when partnership interests are transferred or property is distributed. The…
PLR 200121049: Extra time granted for dual consolidated loss filings
A taxpayer discovered that it had omitted dual consolidated loss filings for its partnerships and other flow through entities. It requested more time to file agreements for two tax years and an…
PLR 200121048: Late S election allowed from corporation's business start date
A corporation's shareholders intended S corporation treatment from the date the business began, and they relied on an attorney to file Form 2553. The form was not filed on time. The IRS found…
PLR 200121047: Buyer and seller receive more time for a stock purchase election
A corporate buyer purchased all the stock of an S corporation, and the buyer and seller intended to make a joint IRC § 338(h)(10) election. Their tax professionals did not file the election by its…
PLR 200121046: Revised funding schedule approved for nuclear plant decommissioning
A utility requested a revised schedule of annual amounts for its nuclear decommissioning fund. Under IRC § 468A, deductions for fund payments depend in part on an IRS schedule and the…
PLR 200121045: Revised funding schedule approved for nuclear plant decommissioning
A utility requested a revised schedule of annual amounts for its nuclear decommissioning fund. Under IRC § 468A, deductions for fund payments depend in part on an IRS schedule and the…
PLR 200121044: Corporate split to resolve shareholder deadlock qualifies for tax deferral
Two shareholders proposed separating a corporation's two businesses to end disputes and management deadlock. The company would transfer one business to a new corporation, then give all of the new…
PLR 200121043: Buyer and sellers receive more time for a stock purchase election
A corporate buyer acquired all the stock of an S corporation, and the buyer and sellers intended to make a joint IRC § 338(h)(10) election. The election was not filed on time despite their reliance…
PLR 200121042: Corporate split to resolve shareholder deadlock qualifies for tax deferral
Two shareholders proposed separating a corporation's two businesses to end disputes and management deadlock. The company would transfer one business to a new corporation, then give all of the new…
PLR 200121041: Late election allowed after purchase of foreign corporation
A corporate parent purchased all the stock of a foreign corporation and intended to make an IRC § 338(g) election, which can treat a qualifying stock purchase as an asset acquisition. The election…
PLR 200121040: Insurer may revoke small company investment income election
A small mutual property insurer had elected under IRC § 831(b) to be taxed only on investment income. After a merger, its business expanded across the state, it changed its reinsurance strategy, and…
PLR 200121039: Parent and sellers receive more time for a stock purchase election
A subsidiary bought all the stock of an S corporation, and its corporate parent and the sellers intended to make a joint IRC § 338(h)(10) election. They missed the filing deadline and requested…
PLR 200121038: Late S election allowed from first shareholder date
A corporation intended S corporation treatment from the date it first had a shareholder. Its accountant later discovered that Form 2553 had not been filed on time. The IRS found reasonable cause for…
PLR 200121037: Late S election allowed from stock issuance date
A corporation's sole shareholder relied on an accountant to file an S corporation election effective when the corporation issued stock and received assets from the shareholder. Form 2553 was not…
PLR 200121036: Corporation receives relief for late S election
A corporation intended S corporation treatment from its incorporation date but did not file its election on time. The IRS found reasonable cause for the missed election under IRC § 1362(b)(5). It…
PLR 200121035: Former resident rebuts expatriation tax avoidance presumption
A former U.S. permanent resident returned to his birth country for work and sought relief from a presumption that expatriation had a principal purpose of avoiding U.S. taxes. He submitted a ruling…
CCA 200121034: Contact with LLC member's corporate parent needs no third party notice
IRS examiners asked whether contacting a corporation related to an LLC under examination would trigger the advance notice rule for third party contacts in IRC § 7602(c). The LLC was taxed as a…
PLR 200121033: Relief granted for S election invalidated by ineligible trust
A corporation filed an S corporation election while an ineligible trust owned some of its shares, making the election ineffective. After discovering the problem, the corporation redeemed all of the…
PLR 200121032: Late S election allowed from asset acquisition date
A corporation with four shareholders intended S corporation treatment from the date it first acquired assets, but it discovered that its election had not been filed on time. The IRS ruled under IRC…
PLR 200121031: Physical injury settlement excluded for one payment year
A widow received settlement payments after asbestos related disease caused her husband's death. She asked whether amounts allocated to survival, wrongful death, and loss of consortium claims were…
PLR 200121030: Revised nuclear decommissioning fund schedule approved with five year limit
An electric utility requested a revised schedule of annual amounts for its nuclear decommissioning fund across several utility commission jurisdictions. Under IRC § 468A, deductions for payments to…
PLR 200121029: Two year nuclear decommissioning funding schedule approved
An electric utility requested a revised schedule of annual amounts for its nuclear decommissioning fund after its utility commission changed when the plant would leave its rate base. The utility…
PLR 200121028: Plant sale receives mixed rulings on decommissioning funds and liabilities
A buyer planned to acquire a nuclear power plant, assume its decommissioning obligation, and receive assets from the seller's qualified and other decommissioning funds. The IRS ruled that…
PLR 200121027: Fund's late dividend election treated as timely
An investment fund intended to elect under IRC § 855(a) to treat dividends distributed after its tax year as paid during that year. A tax manager misunderstood the fund's year end, and its income…
PLR 200121026: Late S election allowed from incorporation date
A corporation with two shareholders intended S corporation treatment from its incorporation date but did not file its election on time. The IRS ruled under IRC § 1362(b)(5) that the election would…
PLR 200121025: Late S election allowed with tax year filing
A corporation with two shareholders intended S corporation treatment from a date after its incorporation but did not file its election on time. The IRS found reasonable cause for the missed election…
PLR 200121024: Proposed trust reformation creates no taxable exchange
Two family trusts shared their current income between two sons, although each trust was primarily intended for one son's family. The shared interests had equalized the trusts while one property had…
PLR 200121023: Proposed trust reformation creates no taxable exchange
Two family trusts shared their current income between two sons, although each trust was primarily intended for one son's family. The shared interests had equalized the trusts while one property had…
CCA 200121022: Inventory method change needs no prior section 481 adjustment
A company acquired another business and later changed its LIFO inventory accounting to the inventory price index computation method. An IRS examiner questioned whether the company first had to make…
PLR 200121021: Revised nuclear decommissioning schedule approved across four jurisdictions
A utility requested a revised schedule of annual amounts for its nuclear decommissioning fund after changes to utility commission assumptions about when the plant would leave the rate base. The…
PLR 200121020: Revised nuclear decommissioning schedule approved across four jurisdictions
A utility requested a revised schedule of annual amounts for its nuclear decommissioning fund after changes to utility commission assumptions about when the plant would leave the rate base. The…
PLR 200121019: Money market funds may deduct premiums paid to their mutual insurer
A group of money market funds bought coverage for issuer default losses from a mutual insurer owned by the participating funds. The funds asked whether their premiums would remain deductible under…
TAM 200121018: Overlapping product groups rejected for foreign sales corporation pricing
A manufacturer used a foreign sales corporation to earn commissions on export sales. To calculate the overall profit percentage under the marginal costing pricing rules, it selected the most…
PLR 200121017: Revised nuclear decommissioning schedule approved across four jurisdictions
A utility requested a revised schedule of annual amounts for its nuclear decommissioning fund after changes to utility commission assumptions about when the plant would leave the rate base. The…
PLR 200121016: Feeder funds may look through master trusts for RIC tests
Regulated investment company feeder funds planned to transfer their portfolios to master trusts in exchange for interests in those trusts. The IRS ruled that each qualifying feeder fund could count…
PLR 200121015: Separate trusts for spouses' interests in a residence qualify as QPRTs
A married couple each planned to transfer a one-half interest in a residence to a separate qualified personal residence trust. They asked whether the property, including its land and small…
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.