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 200012075: Late S corporation election allowed if Form 2553 is filed promptly
A corporation and its shareholders intended S corporation treatment from its first tax year, but the prepared election form was not filed on time. They had filed tax returns consistent with S…
PLR 200012074: Matching trust transfers across states preserve specified tax treatment
Trustees planned to transfer the assets and liabilities of two marital trusts in one state to substantially identical trusts in another state, then terminate the original trusts. The IRS ruled that…
PLR 200012073: IRS grants 30 days to file a late section 338(h)(10) election
A buyer and seller intended to make a joint section 338(h)(10) election after the buyer acquired an S corporation, but missed the filing deadline. The IRS found that the parties acted reasonably and…
PLR 200012072: Late entity classification election treated as timely
A foreign entity with one owner intended to elect treatment as disregarded from its formation date, but its accountant filed the entity classification election late. The IRS found that the entity…
PLR 200012071: Parent gets more time to elect a consolidated return
A parent corporation and its subsidiary missed the deadline to elect consolidated income tax filing for their first intended year, although they later filed a consolidated return. The IRS found that…
PLR 200012070: Buyer and seller receive time for a late section 338(h)(10) election
A purchaser in a consolidated group bought all the stock of an S corporation from its shareholder, and the purchaser and seller missed their intended joint section 338(h)(10) election. The IRS…
PLR 200012069: Missed asset sale election receives a filing extension
The parent of a purchasing group and the seller of an S corporation sought more time for a joint section 338(h)(10) election after its deadline passed. The IRS found that they acted reasonably and…
PLR 200012068: IRS allows a late joint election after an S corporation sale
A purchaser acquired all the stock of an S corporation for notes, but the purchaser and seller did not file their intended section 338(h)(10) election by its due date. The IRS granted the…
PLR 200012067: Late section 338(h)(10) election gets 30 days
A purchasing corporation and the seller of an S corporation intended a joint section 338(h)(10) election but missed the deadline after the stock acquisition. The IRS granted the purchaser's group…
PLR 200012066: Corporation receives conditional relief for an unfiled S election
A corporation with three shareholders had operated as an S corporation from its incorporation but later discovered that it had not filed an election on time. The IRS ruled that the election would be…
PLR 200012065: Late S corporation election may take effect from incorporation
A company with two shareholders intended S corporation status from its incorporation and operated on that basis, but discovered after its first tax year that the election had not been filed on time.…
PLR 200012064: Family business split-off and circular land exchange qualify for tax deferral
Two family groups that jointly owned an S corporation proposed dividing its business so each group could operate separately. The IRS ruled that transferring about half the corporation's assets to a…
PLR 200012063: Family business split-off and circular land exchange qualify for tax deferral
An S corporation owned equally by two family groups sought to divide its operating business after management disagreements. It planned to transfer roughly half its assets to a new corporation and…
PLR 200012062: Family business split-off and circular land exchange qualify for tax deferral
Two family groups each owned half of an S corporation but disagreed about running its business. The corporation proposed moving approximately half its net assets to a new corporation, then…
PLR 200012061: Donations accompanying free sweepstakes entries are deductible
A public university planned to seek donations through a sweepstakes that anyone could enter for free. Its materials would clearly state that donating was optional and would not affect a…
PLR 200012060: Late S corporation election granted for first tax year
A company with one shareholder intended to be an S corporation from incorporation and operated that way, but later discovered that it had missed the election filing deadline. The IRS ruled under §…
PLR 200012059: Missing S election treated as timely after filing
A corporation's sole shareholder intended S corporation status for its first tax year. A law firm prepared Form 2553, and the company believed a bookkeeper had filed it, but no timely election was…
PLR 200012058: Late S election allowed for a company with two shareholders
A two-shareholder company said it had always intended to be an S corporation and operated as one, but discovered after a tax year ended that it had missed the election deadline. The IRS ruled under…
PLR 200012057: S election can cover first taxable year after missed deadline
A corporation with one shareholder intended to elect S status from its incorporation and conducted business on that basis. After its first taxable year ended, it discovered that the election had not…
PLR 200012056: Trustee and situs changes preserve trust's GST exemption
A trust that was irrevocable before September 25, 1985 planned to replace its corporate trustee and move its administration to another state. The trustees represented that no additions had been made…
PLR 200012055: Changing trustees and trust location preserves GST exemption
The trustees of a trust established under a will wanted to replace a corporate trustee and move the trust to another state. They represented that no property had been added after September 25, 1985…
PLR 200012054: Moving a grandfathered trust preserves GST exemption
A testamentary trust for a beneficiary and that person's descendants planned to replace its corporate trustee and move to a different state. The trustees represented that the trust had received no…
PLR 200012053: Trustee replacement does not end grandfathered GST treatment
A trust providing lifetime income to a beneficiary and a remainder for descendants planned to replace one of its trustees and move to another state. The trustees said no property had been added…
PLR 200012052: Grandfathered GST trust may change corporate trustee and situs
A trust that had been irrevocable on September 25, 1985 wanted to replace its corporate trustee and transfer its situs to a different state. Its trustees represented that there had been no later…
FSA 200012051: University facility, campus sales, and outside lab fees under UBIT rules
IRS Field Service Advice considered three revenue sources of an exempt university and its medical center. It agreed that a weight-management facility's income was related to the university's…
PLR 200012050: Extension granted for late entity classification election
An entity formed as a state-law corporation later converted to a state-law limited partnership but wanted to continue being taxed as a C corporation. It missed the deadline to file Form 8832 for…
FSA 200012049: Tax Court jurisdiction and claims for tax interest
A consolidated corporate group challenged how the IRS had calculated interest across several tax years. Field Service Advice explained that the Tax Court could determine interest tied to…
CCA 200012048: Reporting agents need new authorizations to change Form 941 filing medium
A service center asked whether reporting agents authorized only to file clients' Form 941 returns on magnetic tape could switch to electronic filing by notifying clients and keeping their responses.…
CCA 200012047: Betting tickets and vouchers are not cash under § 6050I
Chief Counsel considered a betting parlor customer who combined currency with a winning ticket or voucher to place a bet exceeding $10,000. Section 6050I requires businesses to report certain…
FSA 200012046: Subsidiary departure accelerates an intercompany property loss
A consolidated group's subsidiary distributed property worth less than its tax basis to its parent just before the parent sold the subsidiary's stock to an unrelated buyer. Field Service Advice…
PLR 200012045: Governmental deferred compensation plan qualifies under § 457
A state political subdivision sought a ruling on its amended deferred compensation plan for employees. The IRS ruled that the plan qualified as an eligible § 457(b) plan and that compensation and…
PLR 200012044: S election steps preserve a trust's GST exemption
A trust holding stock in a C corporation planned to consent to the corporation's S election, elect treatment as an electing small business trust, and sign a shareholder agreement intended to protect…
PLR 200012043: Trust's S corporation steps leave GST exemption intact
A trust created through a daughter's exercise of powers under two older family trusts held stock in a corporation planning an S election. Its trustee proposed consenting to that election, electing…
PLR 200012042: ESBT and shareholder agreement steps preserve GST exemption
A trust for a grandchild and her descendants held shares of a corporation that planned to elect S corporation status. The trustee planned to consent to the company's election, elect treatment as an…
PLR 200012041: Family trust keeps GST exemption after S election steps
After a family trust beneficiary died without exercising a testamentary power of appointment, part of the trust became a separate trust for one descendant and his descendants. Its main asset was…
PLR 200012040: Trust remains GST exempt after proposed S corporation actions
A descendant's trust formed from a family trust held stock in a C corporation that proposed to become an S corporation. The trustee planned to consent to that election, elect small business trust…
PLR 200012039: Trust's proposed S election actions preserve GST status
A trust for a grandson and his descendants was formed from shares of older irrevocable family trusts and held stock in a C corporation. The corporation planned an S election, and the trustee…
PLR 200012038: Releasing a charitable appointment power preserves trust's GST exemption
A daughter with a limited power to appoint trust property released only her lifetime power to direct it to charities, retaining a power to appoint it among her descendants. The IRS ruled that this…
PLR 200012037: Testamentary trust keeps GST exemption through S election steps
A son exercised a limited power under his parent's will to create a trust for one beneficiary and his descendants. The IRS found that this exercise did not count as a post-September 25, 1985…
PLR 200012036: Granddaughter's trust retains GST exemption after S election steps
Two grandparents placed corporate stock in irrevocable trusts, and part of that property became a separate trust for a granddaughter and her descendants. The corporation proposed to elect S status.…
PLR 200012035: S corporation elections do not disturb granddaughter's GST trust
A granddaughter's trust owned shares in a corporation that wanted to become an S corporation. Its trustee asked whether consenting to that election, making an electing small business trust election,…
PLR 200012034: Grandson's trust may take S election steps without losing GST exemption
A separate trust for a grandson and his descendants held stock in a C corporation that planned to elect S status. Its trustee proposed consenting to the corporation's election, electing treatment as…
PLR 200012033: Grandson's trust retains GST exemption with S corporation steps
A grandson's trust received shares from two older family trusts and held stock in a corporation seeking S status. The trustee wanted to consent to the S election, make an electing small business…
PLR 200012032: Appointed trust keeps GST exemption after S corporation steps
A daughter used limited testamentary powers under her parents' wills to create a trust for a beneficiary and his descendants. The IRS found that property entering the trust through that exercise was…
PLR 200012031: Proposed S corporation actions leave grandfathered trust exempt
A family trust for a grandson held corporate shares traceable to two irrevocable trusts established by his grandparents. The corporation planned to elect S status, and the grandson's trustee…
PLR 200012030: Daughter's trust retains GST exemption through S election actions
An irrevocable family trust for a daughter and her descendants held stock in a corporation proposing to elect S status. The trustee planned to consent to the corporation's election, elect treatment…
PLR 200012029: Appointed trust's GST exemption survives S corporation steps
A son used a limited testamentary power under a parent's will to create a trust for a beneficiary and his descendants. The IRS concluded that property entering the trust through that power was not a…
PLR 200012028: Appointed family trust keeps GST exemption with S election steps
A daughter used testamentary powers under two older family trusts to create a trust for a beneficiary and his descendants. The trust's principal asset was corporate stock, and its trustee proposed…
PLR 200012027: Descendant trust retains GST exemption after S election actions
After a daughter died without exercising a testamentary power of appointment, part of an older family trust passed to a separate trust for a female descendant and her descendants. That trust's main…
PLR 200012026: Trust created under son's will keeps GST exemption
A son exercised limited testamentary powers under two older family trusts to create a trust for a beneficiary and his descendants. The IRS found that this exercise did not count as a post-September…
PLR 200012025: Grandson's trust may support S election without GST loss
Two grandparents funded older irrevocable trusts with shares of a corporation, and a separate trust for a grandson later held part of that stock. The corporation proposed an S election. The trustee…
PLR 200012024: Trust formed by son's appointment keeps GST exemption
A son exercised a limited testamentary power under a parent's will to establish a trust for a female beneficiary and her descendants. The IRS ruled that this exercise did not amount to a…
PLR 200012023: Grandson's trust preserves GST exemption through S election steps
Two irrevocable trusts funded with corporate shares by grandparents later supplied a separate trust for a grandson and his descendants. The company planned an S election, and the grandson's trustee…
PLR 200012022: Granddaughter trust keeps GST exemption with S election steps
A son died without exercising a limited power of appointment over an older irrevocable family trust, and part of his trust became a trust for a granddaughter and her descendants. That trust held…
PLR 200012021: Appointed trust's S election steps preserve GST exemption
A son exercised testamentary powers under two irrevocable trusts established by his parents and directed property into a trust for a beneficiary and his descendants. The IRS ruled that this exercise…
PLR 200012020: S election steps preserve a trust's GST exemption
An irrevocable trust for a daughter was divided among trusts for her descendants after her death. One descendant's trust held stock in a corporation planning to elect S corporation status. Its…
PLR 200012019: S corporation election does not end a trust's GST exemption
An irrevocable trust for a beneficiary and her descendants held stock in a corporation planning an S election. The trustee proposed to consent to the election, elect treatment as an electing small…
PLR 200012018: S election steps leave descendant's trust GST exempt
After a daughter died without exercising her limited power of appointment, her trust property passed into three trusts for her descendants. One trust held stock in a corporation planning to elect S…
PLR 200012017: Appointed trust keeps GST exemption through S election steps
A daughter exercised testamentary powers over two older irrevocable trusts and directed property into three trusts for her descendants. One trust held stock in a corporation planning an S election.…
PLR 200012016: Trust keeps GST exemption after proposed S election steps
After a daughter died without exercising a limited power of appointment, her trust property was divided among four trusts for her descendants. One descendant's trust held stock in a corporation…
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.