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 1222009: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222008: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222007: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1222006: IRS approves pooled income fund terms and related tax treatment
The IRS ruled on six questions concerning a tax-exempt organization’s proposed pooled income fund. It concluded that several provisions in the fund’s governing instrument would not prevent pooled…
PLR 1221012: IRS grants more time for a rental real estate election
The IRS granted married taxpayers 120 additional days to make an election under IRC § 469(c)(7)(A) to treat all of their interests in rental real estate as one rental real estate activity. The…
PLR 1221011: IRS approves a revised nuclear decommissioning-fund schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's share of the costs of decommissioning a nuclear power plant under IRC § 468A. The taxpayer had used an independent…
CAPCO tax credits create income when used to pay note obligations
Chief Counsel's advice considers a state-certified capital company whose investors received premium tax credits and used them to offset principal and interest owed on notes issued by the company.…
PLR 1220004: Unamortized debt issuance costs remain deductible separately from COD income
The IRS ruled that a taxpayer's unamortized debt issuance costs would remain deductible as a separate item when the taxpayer's debts were canceled or exchanged under a bankruptcy plan. The costs…
PLR 1211001: Tax-exempt employer's deferred compensation plan qualifies under section 457(b)
A tax-exempt employer proposed an unfunded deferred compensation plan for a select group of management and highly compensated employees. The IRS ruled that the plan was an eligible deferred…
PLR 1208036: IRS approves tax treatment for four bankruptcy liquidation trusts
A corporation in Chapter 11 bankruptcy proposed a liquidation plan that would create four trusts to resolve different groups of claims and distribute remaining assets. The IRS ruled that the…
PLR 1208033: IRS grants extra time to make a LIFO inventory election
A parent corporation failed to attach Form 970 when a newly acquired subsidiary first began using the LIFO inventory method. The group later discovered the omission while reviewing its financial…
PLR 1203016: IRS approves nuclear decommissioning deduction and ruling schedules
The IRS approved a taxpayer’s request for a schedule of deduction amounts and a revised schedule of ruling amounts for a nuclear decommissioning fund. The taxpayer had acquired interests in a…
CCA 1203013: Settlement compensation may be a nontaxable return of capital
Chief Counsel advice addressed the tax treatment of compensation received after a manufacturer breached a purchase agreement and returned the taxpayer's deposits. The returned deposits were not…
PLR 1203001: IRS approves nuclear decommissioning deduction and ruling schedules
A corporation that owns and operates a nuclear plant requested a deduction schedule and a revised schedule of ruling amounts for its nuclear decommissioning fund. The IRS determined that the…
CCA 1202021: CCA addresses removing an IRC section 163(j) interest limit
Chief Counsel advice considered whether removing an IRC section 163(j) limitation on a corporation's interest deduction would be a change in accounting method under section 446. The advice concluded…
CCA 1151022: Chief Counsel addresses accounting-method consent for advance payments
Chief Counsel considered a taxpayer that defers advance payments from multiple-deliverable contracts for federal income tax purposes under Rev. Proc. 2004-34. If the taxpayer adopts the new…
PLR 1151002: Governmental deferred compensation plan qualifies under section 457(b)
A state board asked whether its amended model deferred compensation plan for local governmental employers qualified as an eligible deferred compensation plan under section 457(b). The IRS ruled that…
PLR 1151001: Governmental deferred compensation plan qualifies under section 457(b)
A state board asked whether its amended deferred compensation plan for state and local governmental employers qualified as an eligible deferred compensation plan under section 457(b). The IRS ruled…
PLR 1150028: IRS granted extra time to file LIFO inventory elections
The IRS granted a parent company and a subsidiary an extension of time to file Forms 970 to elect the LIFO inventory method. The taxpayers had used LIFO after failing to make the required elections…
PLR 1150025: IRS granted extra time to file LIFO inventory elections
The IRS granted a parent company and its subsidiaries an extension of time to file Forms 970 to elect the LIFO inventory method. The taxpayers had used LIFO after failing to make the required…
PLR 1150020: IRS approved a benefit cap without ending a deferred-compensation grandfather rule
The IRS considered an amendment to a nonprofit organization's deferred-compensation plan. The plan used a fixed formula and was subject to a grandfather rule for certain amounts deferred under a…
Residual-value insurance contract is not insurance for federal tax purposes
The IRS concluded that a contract labeled as insurance against market decline was not a contract of insurance for federal income tax purposes. The contract protected against a lower-than-predicted…
PLR 1148003: Future insurance rate credits were not taxable in Year 3
The IRS considered when a time-value credit from an insurer's refund of erroneously collected state premium taxes became income to a multiple-employer VEBA. The credit could be used only through…
PLR 1147007: IRS approves a revised nuclear decommissioning reserve schedule
A nuclear power plant owner asked the IRS to approve a revised schedule of amounts it could contribute to a nuclear decommissioning reserve fund. The IRS concluded that the owner was an eligible…
PLR 1146011: IRS approves a revised nuclear decommissioning-fund ruling schedule
The IRS approved a revised schedule of ruling amounts for a taxpayer's nuclear decommissioning fund. The taxpayer owned an interest in a nuclear plant and supported its proposed schedule with a…
PLR 1146010: IRS approves deduction and revised ruling schedules for a nuclear decommissioning fund
The IRS approved a taxpayer's schedule of deduction amounts and a revised schedule of ruling amounts for a nuclear decommissioning fund. The taxpayer requested transitional relief under IRC § 468A…
PLR 1146009: IRS approves deduction and revised ruling schedules for a decommissioning fund
The IRS approved a taxpayer's schedule of deduction amounts and revised schedule of ruling amounts for a nuclear decommissioning fund. The taxpayer's plant was already being decommissioned, and the…
Taxpayers under examination may file a statement for an advance-payment accounting change
Chief Counsel's Office advice addressed how a taxpayer under examination could satisfy the filing requirements for an accounting-method change involving advance payments. The memo concluded that,…
IRS approves a revised nuclear decommissioning funding schedule
A utility company asked the IRS to approve a revised schedule of annual amounts that it could contribute to a nuclear decommissioning reserve fund. The IRS concluded that the taxpayer had a…
Nuclear decommissioning special transfer and revised funding schedules approved
A nuclear plant owner asked for a schedule of deduction amounts for a special transfer to its decommissioning fund and a revised schedule of future ruling amounts. The request relied on transitional…
Nuclear decommissioning special transfer and revised ruling schedule approved
A nuclear plant owner asked for approval to make a special transfer to its decommissioning fund and to receive revised schedules for deductions and future ruling amounts. The request relied on…
PLR 1144010: IRS approves a revised nuclear decommissioning-fund schedule
A nuclear power plant owner asked the IRS to revise its schedule of ruling amounts for deductible contributions to a nuclear decommissioning fund. The IRS found that the taxpayer had a qualifying…
PLR 1144008: IRS approves a revised nuclear decommissioning-fund schedule after funding changes
A nuclear power plant owner asked the IRS to revise its nuclear decommissioning-fund ruling-amount schedule after a public utility commission approved additional funding. The IRS found that the…
PLR 1143010: IRS approves revised deduction and ruling schedules for a nuclear decommissioning fund
A holding company with an ownership interest in a nuclear power plant requested schedules for deductions and ruling amounts related to the plant's decommissioning fund. The IRS approved a special…
PLR 1143009: IRS approves special-transfer deductions and revised ruling amounts for a nuclear decommissioning fund
A holding company with an indirect ownership interest in a nuclear power plant requested schedules for deductions and ruling amounts related to the plant's decommissioning fund. The IRS approved a…
PLR 1143008: IRS approves special-transfer deductions and revised ruling amounts for a nuclear decommissioning fund
A holding company with an indirect ownership interest in a nuclear power plant requested schedules for deductions and ruling amounts related to the plant's decommissioning fund. The IRS approved a…
PLR 1143007: IRS approves revised ruling amounts for a nuclear decommissioning fund
A subsidiary that owned and operated a nuclear power plant requested an elective review of its existing schedule of ruling amounts under section 468A. The request followed increases in…
PLR 1143003: IRS approves revised ruling amounts for a nuclear decommissioning fund
A subsidiary that owned and operated a nuclear power plant requested an elective review of its existing schedule of ruling amounts under section 468A. The request followed increases in…
TAM 1142020: Restructured commodity call options remained options and hedges
The IRS analyzed a taxpayer's written call options on a commodity after the contracts were restructured. It concluded that the contracts remained options, so losses from closing them were capital…
PLR 1142009: IRS approves revised nuclear decommissioning deduction and ruling schedules
The IRS approved a nuclear plant owner's requested schedule of deduction amounts and revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The ruling allows a…
PLR 1142008: IRS approves transitional nuclear decommissioning schedules
The IRS approved a nuclear plant owner's requested initial schedule of deduction amounts and revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The ruling allows…
PLR 1142007: IRS approves nuclear decommissioning deduction and ruling schedules
The IRS approved a nuclear plant owner's requested schedule of deduction amounts and revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The ruling permits a…
PLR 1142002: IRS approves a governmental deferred compensation plan
The IRS approved a restated deferred compensation plan maintained by a municipal corporation as an eligible governmental plan under IRC § 457(b). The ruling confirms that properly deferred…
PLR 1141006: Nuclear decommissioning deduction and ruling schedules approved
A taxpayer with a direct ownership interest in a nuclear power plant requested a schedule of deduction amounts for a special transfer to its nuclear decommissioning fund and a revised schedule of…
PLR 1141005: Nuclear decommissioning deduction and ruling schedules approved
A taxpayer with a direct ownership interest in a nuclear power plant requested a schedule of deduction amounts for a special transfer to its nuclear decommissioning fund and a revised schedule of…
PLR 1140022: IRS approves nuclear decommissioning fund deduction and ruling schedules
The IRS approved a taxpayer’s request for a schedule of deduction amounts and a revised schedule of ruling amounts for a nuclear decommissioning fund. The ruling permits a special transfer of a…
PLR 1140008: Intra-group sales and rescissions disregarded for federal tax purposes
A corporate group asked how several completed transfers among related companies should be treated after the group discovered that the transfers had moved assets outside the intended business…
PLR 1140005: Nuclear decommissioning deduction and ruling schedules approved
A nuclear plant owner asked for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The request relied on transitional…
PLR 1140004: Nuclear decommissioning deduction and ruling schedules approved
A nuclear plant owner asked for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The request relied on transitional…
PLR 1139002: IRS approved nuclear decommissioning deduction and ruling-amount schedules
The IRS approved a nuclear power plant owner's request for a schedule of deduction amounts and a revised schedule of ruling amounts for its nuclear decommissioning fund. The ruling applied…
PLR 1136006: Taxpayer granted more time to file LIFO elections
A parent corporation asked for more time to file Forms 970 for fourteen subsidiaries that had used the LIFO inventory method but had not timely attached the required election forms. The IRS…
PLR 1136003: Nuclear decommissioning fund deduction and ruling schedules approved
A holding company that owned an interest in a nuclear power plant asked the IRS for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear…
CCA 1135030: Unamortized hedge gain must be recognized when debt is repurchased
Chief Counsel Advice addressed whether a taxpayer could defer the unamortized gain from an interest-rate hedge when it elected to defer cancellation-of-debt income under IRC § 108(i). The hedge was…
CCA 1135029: IRS requests more facts before deciding accounting-method issues
Chief Counsel Advice addressed the accounting method of an S corporation that provided health-related consulting services and had expanded into supplying equipment. The questions concerned whether…
CCA 1132021: IRS advised on mark-to-market treatment of an energy contract
Chief Counsel Advice considered whether an energy company was a dealer in commodities and could apply mark-to-market treatment under section 475(e) to parts of a long-term electricity agreement. The…
PLR 1131002: IRS granted more time to elect to treat rental real estate interests as one activity
The taxpayer was in a real property business and qualified to elect to treat all interests in rental real estate as one rental real estate activity. The taxpayer filed a return without the statement…
PLR 1130001: IRS grants more time to file a LIFO inventory election
The IRS granted a taxpayer 30 days to file Form 970 and adopt the LIFO inventory method for inventory transferred in a section 351 transaction. A subsidiary had transferred inventory to a newly…
PLR 1128017: IRS treats a guaranteed account benefit contract as an annuity
An insurance company asked how a proposed contract would be treated for federal tax purposes. The contract would charge a fee and provide a lifetime benefit if an investment account fell below a…
PLR 1128009: IRS grants more time for a rental real estate election
A married couple asked for more time to elect to treat all of their rental real estate interests as one rental real estate activity for passive activity purposes. They had qualified for the election…
PLR 1128007: IRS permits a construction company to revoke its look-back method election
A parent corporation asked to revoke its subsidiary's election to use the Simplified Marginal Impact Method for calculating look-back interest on long-term construction contracts. The subsidiary…
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.