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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
CCA 1052017: An Algerian gross-basis levy did not qualify as an income tax or an in-lieu tax
Chief Counsel Advice considered whether Algeria's Exceptional Profits Tax qualified for treatment under IRC §§ 901 or 903. The advice states that the levy appeared to be based on gross income and…
PLR 1049021: Corporation may revoke foreign-tax safe harbor elections
This ruling concerns a corporation that used the regulatory safe harbor method to calculate the portion of foreign levies eligible for foreign tax credits. The corporation had used the method for…
PLR 1049001: IRS denies § 9100 relief for late DISC election
A domestic corporation asked for more time to file Form 4876-A to elect interest charge DISC status for an earlier tax year. The IRS determined that the applicable election deadline came from the…
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.