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 200050020: Managed property rents excluded from S corporation passive income test
An S corporation with accumulated C corporation earnings and profits received rental income from properties held directly and through a qualified S subsidiary's partnership interests. Its staff and…
PLR 200050019: Two shareholder company receives late S election relief
A company with two shareholders intended to elect S corporation status from a specified tax year but discovered that it had missed the filing deadline. It asked the IRS to treat the election as…
PLR 200050018: Ineligible corporate shareholders do not end S status after corrective redemptions
An S corporation issued shares to three other corporations, which were ineligible S corporation shareholders. After discovering the problem, it promptly arranged to redeem their shares at the…
PLR 200050017: Later stock recapitalization leaves prior spin off ruling intact
A corporation had previously received an IRS ruling for a section 355 distribution of a subsidiary's stock after the subsidiary issued two classes of common shares with different voting rights.…
PLR 200050016: Trust split and investment update preserve GST exemption
A trust that became irrevocable before September 25, 1985, proposed splitting into two equal trusts for the settlor's children and their descendants. The trustee also sought to update investment…
PLR 200050015: Tribal council qualifies as an Indian tribal government
A tribal council asked whether it qualified as an Indian tribal government for federal tax purposes. The tribe appeared on the Department of the Interior's list of recognized tribal entities, and…
CCA 200050014: Section 7519 required payment is a tax for refund deadline
District counsel asked whether an S corporation's required payment under section 7519 counted as a tax when applying the deadline for refund or credit claims. The corporation had elected a tax year…
CCA 200050013: Tax motive alone does not validate circular affiliate loans
Field counsel asked whether reducing tax could be a valid business purpose for transactions between affiliated corporations. Chief Counsel said a real transaction can be respected even when tax…
PLR 200050012: Corporation's late S election effective from incorporation
A newly incorporated company intended to elect S corporation status from its incorporation date but filed no timely election. The IRS found reasonable cause for the missed deadline under section…
PLR 200050011: Late S election recognized from incorporation date
A corporation intended to be treated as an S corporation from its incorporation date but did not file the election on time. The IRS found reasonable cause for the missed deadline and granted relief…
PLR 200050010: Master feeder funds may look through portfolios and aggregate certain gains
Six feeder funds invested through three portfolios treated as partnerships. The IRS ruled that each feeder fund qualifying as a regulated investment company could count its share of a portfolio's…
PLR 200050009: Accountant's error permits revocation of installment sale opt out
A partnership sold property for part cash and a seller financed mortgage. It instructed its accountant to report the gain using the installment method, but the accountant mistakenly reported the…
PLR 200050008: Governmental deferred compensation plan qualifies under section 457
A political subdivision amended its deferred compensation plan and asked whether it qualified under section 457. The plan limited deferrals and distribution timing, allowed the specified small…
PLR 200050007: Missed S election deadline relieved if Form 2553 filed promptly
A company intended to elect S corporation status when it was incorporated, but it missed the Form 2553 filing deadline. The IRS found reasonable cause under section 1362(b)(5) and agreed to treat…
PLR 200050006: Sole shareholder's late S election qualifies for relief
A newly incorporated company's sole shareholder relied on an attorney to file Form 2553 for S corporation status from the first tax year. The attorney missed the deadline. The IRS found reasonable…
TAM 200050005: Environmental cleanup costs do not qualify for claim of right relief
A manufacturer paid to capture or redispose of waste from earlier years and remediate related contamination. It sought the special tax calculation under section 1341 instead of taking current…
PLR 200050004: Buyer receives the fuel production credit after acquiring oil and gas properties
A buyer purchased interests in oil and gas properties while the seller retained two limited production payments, a right to payments under a recourse note, and a contingent interest in any…
CCA 200050003: Apply the Indian employment credit wage cap separately to each year
Chief Counsel advised how to compute the Indian employment credit under section 45A. The $20,000 limit on wages and health insurance costs applies to each qualified employee separately in the 1993…
CCA 200050002: Community income relief does not apply to income earned after divorce
A former spouse sought section 66(c) relief from tax on income from a partnership interest acquired during marriage but held after divorce. Chief Counsel advised that section 66(c) did not apply to…
CCA 200050001: Thrift cannot deduct claimed loss of supervisory goodwill
A thrift acquired another thrift and recorded supervisory goodwill for regulatory accounting. After a change in capital rules, it claimed a tax loss for that goodwill. Chief Counsel advised that the…
PLR 200049043: Conditional pension funding waiver granted for 1999
A company sought relief from the minimum funding standard for its defined benefit pension plan after financial difficulties affected its corporate group. The IRS granted a conditional waiver for the…
PLR 200049042: Conditional funding waiver requires later contributions and a plan amendment
The sponsor of a pension plan requested a minimum funding waiver for the 1999 plan year after several years of negative working capital and operating losses. The IRS granted the waiver under section…
PLR 200049041: Cash ESOP dividends qualify for deduction and avoid early distribution tax
A company planned to pay dividends on stock held in its employee stock ownership plan and let active employees increase salary deferrals by the dividend amount. The IRS ruled that the company could…
PLR 200049040: IRS waives additional pension funding excise tax
A company requested waivers of the 100 percent excise tax under section 4971(b) for funding deficiencies in its money purchase pension plan. The IRS granted the waivers for the plan years identified…
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.