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 200012015: Appointed trust's S election steps preserve GST exemption
A son exercised limited testamentary powers over two older irrevocable trusts after September 25, 1985, directing property into three trusts for beneficiaries and their descendants. The IRS found…
PLR 200012014: Appointed trust retains GST exemption after S election steps
Two grandparents created trusts under their wills for their children. A daughter later exercised limited testamentary powers over those trusts and directed property into four trusts for…
PLR 200012013: Descendant's trust keeps GST exemption through S election
An irrevocable trust was divided for a grandparent's children. After one son died without exercising his limited power of appointment, his share passed into three trusts for his descendants. One…
PLR 200012012: S election steps preserve a trust's GST exemption
Two grandparents created trusts for their children under their wills. A daughter exercised testamentary powers and directed property into three trusts, one of which held corporate stock for a…
PLR 200012011: S election steps preserve a grandchild's trust GST exemption
Two grandparents established irrevocable trusts holding corporate stock. After an initial period of charitable distributions, the trusts' property was allocated among twelve separate shares for…
PLR 200012010: Grandchild trust's S election steps preserve GST exemption
Two grandparents created irrevocable trusts whose property was later divided among twelve shares for grandchildren and their descendants. One share held stock in a corporation planning to elect S…
PLR 200012009: S election does not disturb grandchild trust's GST exemption
Two grandparents' irrevocable trusts held corporate stock and later distributed their property among twelve shares for grandchildren and descendants. One beneficiary's share held stock in a…
PLR 200012008: S election steps leave descendant trust GST exempt
Two grandparents established trusts for their children under their wills. A daughter exercised testamentary powers and directed property into three trusts, including one for a beneficiary and his…
PLR 200012007: Appointed trust retains GST exemption through S election
Two grandparents created trusts for their children under their wills. A daughter exercised limited testamentary powers and directed property into four trusts for beneficiaries and their descendants.…
PLR 200012006: S election steps preserve descendant trust GST exemption
An irrevocable trust was divided into shares for a grandparent's children. When one son died without exercising his limited testamentary power, his share passed into three trusts for his…
PLR 200012005: S election actions preserve trust's GST exemption
Two grandparents created trusts for their children under their wills. A daughter exercised testamentary powers and directed property into three trusts for beneficiaries and their descendants. One…
PLR 200012004: S election steps leave descendant's trust GST exempt
An irrevocable trust was divided into shares for a grandparent's children. A daughter's share passed into three trusts for her descendants after she died without exercising her limited testamentary…
PLR 200012003: Appointed trust keeps GST exemption after S election steps
Two grandparents created trusts for their children under their wills. A daughter exercised limited testamentary powers and directed property into four trusts for beneficiaries and their descendants.…
CCA 200012002: Merger agreement does not bar customer paper mark to market election
A seller of nonfinancial goods elected out of the customer paper exception and sought to mark certain receivables to market under § 475 for earlier tax years. Examination asked whether restrictions…
PLR 200011072: Daughter's life expectancy sets inherited plan payout period
A retirement plan participant named a trust as the beneficiary of his plan account and died after required minimum distributions had begun. His daughter could receive income and principal from two…
PLR 200011071: Public pension service credit payments qualify as employer contributions
A state administered pension plan let current employees buy optional service credit, including credit for amounts they had previously withdrawn. Employees could make an irrevocable payroll deduction…
PLR 200011070: Highway patrol service credit payments qualify as employer contributions
A state highway patrol pension plan offered active employees the option to buy service credit through irrevocable payroll deductions. Under the proposed arrangement, their employer would pay the…
PLR 200011069: Foundation's matching grant set aside qualifies as a distribution
A private foundation proposed to reserve up to a specified amount of income for a matching grant to another tax exempt organization. It represented that the money would be paid for that project…
PLR 200011068: Sheriffs' service credit payments qualify as employer contributions
A state administered pension plan for sheriffs and investigators proposed an irrevocable payroll deduction option for buying service credit. Under the arrangement, employers would pay the amounts…
PLR 200011067: Police service credit payments qualify as employer contributions
A state administered pension plan covering certain city police officers proposed an irrevocable payroll deduction option to buy service credit. Employers would pay elected amounts directly to the…
PLR 200011066: Judicial pension service credit payments qualify as employer contributions
A state administered pension plan for certain judges and justices proposed an irrevocable payroll deduction option to buy optional service credit. The employer would pay the elected amounts directly…
PLR 200011065: Public safety service credit payments qualify as employer contributions
A state administered pension plan covered several groups of public safety and inspection employees. It proposed an irrevocable payroll deduction option for buying optional service credit, with…
PLR 200011064: Firefighters' service credit payments qualify as employer contributions
A state administered pension plan for full-paid and certain part-paid firefighters proposed an irrevocable payroll deduction option for buying optional service credit. Employers would pay elected…
PLR 200011063: Insurance reserves and proceeds can fund employee benefits through a VEBA
An employer had a tax exempt voluntary employees beneficiary association, or VEBA, that had funded retiree benefits. It transferred one former insurer's premium reserve to the VEBA and proposed to…
PLR 200011062: Surviving spouse may transfer IRA assets through trust into her own IRA
A deceased IRA owner's trust was named as the beneficiary of his IRA. His surviving spouse was the trust's trustee and income beneficiary, and she could demand all of its principal. The IRS ruled…
PLR 200011061: Foreign law change leaves subsidiary domestic treatment election intact
A U.S. corporate group had elected under section 1504(d) to treat four subsidiaries in a neighboring country as domestic corporations for federal income tax purposes. A change in that country's law…
PLR 200011060: Power contract termination qualifies as an involuntary conversion
An independent power producer agreed to end its long-term electricity purchase agreement with a utility that had threatened to condemn its generating facility. The IRS ruled that the agreement and…
PLR 200011059: Utility buyout qualifies for involuntary conversion treatment
A hydroelectric power producer ended its long-term electricity purchase agreement and sold its facility to a utility after the utility threatened to use eminent domain. The IRS ruled that the…
PLR 200011058: Child's withdrawal rights permit trust to hold S corporation shares
A parent planned to give S corporation stock to a trust for a child who could withdraw each contribution after receiving notice. The IRS ruled that the child would be treated as the owner of the…
PLR 200011057: Restated power contracts replace an involuntarily converted agreement
A power producer ended its original electricity purchase agreement after a utility threatened to condemn its generating facility. The producer received cash, utility shares, and two new contracts: a…
PLR 200011056: Trust receiving voting interests may hold S corporation shares
A parent planned to give voting trust interests tied to S corporation stock to a trust for a child. The child could withdraw each contribution after receiving notice. The IRS ruled that the child's…
PLR 200011055: Voting trust interests may be gifted to an S corporation shareholder trust
A parent planned to give voting trust interests tied to S corporation stock to a trust for a child. The child could withdraw each contribution after receiving notice. The IRS ruled that the child…
PLR 200011054: Child's withdrawal rights keep stock gift trust eligible for S corporation shares
A parent planned to give S corporation stock to a trust for a child. The trust gave the child a right to withdraw each contribution after receiving notice. The IRS ruled that the child would be…
PLR 200011053: Power agreement buyout qualifies as an involuntary conversion
A power producer accepted cash and stock to end its electricity purchase agreement after a utility threatened to condemn its generating facility. The IRS ruled that the agreement and facility formed…
PLR 200011052: Power agreement termination and related payments receive favorable treatment
A power producer received cash and stock to end its electricity purchase agreement after a utility threatened to condemn its generating facility. The IRS ruled that the agreement and facility formed…
PLR 200011051: Foundation may inherit partnership interests with temporary debt and holdings relief
A private foundation was named to receive a donor's interests in nine partnerships, some of which owned mortgaged real estate or operated businesses. The IRS ruled that receiving and holding the…
CCA 200011049: Counsel found a corporate tax refund claim untimely and a collection damages suit too late
A taxpayer advocate asked Chief Counsel about employment taxes paid with a corporate check signed by a woman who said she had been threatened with seizure of her personal property. Counsel said she…
CCA 200011048: Partner's tax on discharged partnership debt requires deficiency procedures
Chief Counsel advised a service center on how to assess a partner's tax after a partnership reports cancellation of indebtedness income. The partnership's income amount and allocation among partners…
CCA 200011047: Divide disputed joint estimated tax payments by each spouse's separate tax
Chief Counsel addressed joint estimated tax payments made by spouses who later file separate returns. The spouses may agree how to divide the payments, including giving all the credit to one spouse.…
CCA 200011046: Counsel guidance on bankruptcy offers in compromise received before 2000
Chief Counsel described how to review offers in compromise from taxpayers in bankruptcy that the IRS received before January 1, 2000. Until that date, Collection would consider the offers if the…
PLR 200011045: Former resident's green card surrender lacked a principal tax avoidance purpose
A former U.S. permanent resident surrendered her green card after moving with her husband to her birth country. Her net worth exceeded the threshold that could trigger a presumption of tax avoidance…
CCA 200011044: Virgin Islands tax cover overs differ from refunds
Chief Counsel addressed two requests to move tax money from the United States to the U.S. Virgin Islands. For taxes collected from a qualifying individual resident, the section 7654 transfer to the…
PLR 200011043: Former resident's move to spouse's home country lacked a tax avoidance purpose
A former U.S. permanent resident surrendered his green card after retiring and moving with his wife to the country where she was born. His net worth exceeded the threshold that could trigger a…
PLR 200011042: IRS found a principal tax avoidance purpose in citizenship renunciation
A former U.S. citizen who was born in another country asked whether renouncing his U.S. citizenship had a principal purpose of avoiding U.S. tax. His net worth exceeded the threshold discussed in…
PLR 200011041: Insurance business transfer qualifies as a corporate reorganization
A corporate group planned to move nearly all assets and insurance business of one life insurer to another group insurer through reinsurance and an assignment, while leaving the first company with…
PLR 200011040: Late S corporation election allowed if filed within 60 days
A corporation and its two shareholders intended S corporation treatment from the corporation's first tax year, but its accountant did not timely file Form 2553. The corporation initially filed an S…
PLR 200011039: Job transfer home did not give up a green card for tax avoidance
A permanent resident returned with his wife to their birth country after his employer transferred him there, and he surrendered his green card. His net worth exceeded the section 877 threshold that…
PLR 200011038: Spouse's green card surrender after job transfer lacked a tax avoidance purpose
A permanent resident followed her husband back to their birth country after his employer transferred him there, and she surrendered her green card. Her net worth exceeded the section 877 threshold…
PLR 200011037: Former resident received more time to request an expatriation ruling
A former U.S. resident who surrendered her green card missed the deadline to request an IRS ruling on whether expatriation had a principal tax avoidance purpose. She said she was living abroad when…
PLR 200011036: Partnership to corporation transfer receives nonrecognition treatment
A publicly traded partnership planned to move assets into a new corporation that intended to elect real estate investment trust status, then distribute the corporation's stock to its partners. The…
PLR 200011035: Foreign mutual insurer's demutualization and holding company formation
A foreign mutual life insurer planned to become a stock insurer under a new holding company, with eligible policyholders receiving shares, cash, or policy credits for their mutual ownership rights.…
PLR 200011034: Housing credit agency may correct building IDs and address in allocation
A housing project was redesigned, but its low income housing credit carryover allocation did not reflect the revised number of residential buildings or the address of a newly constructed building.…
PLR 200011033: Three business split offs qualify as reorganizations
A corporation owned by siblings and a family partnership operated a business at several locations. Its owners wanted to run portions of the business separately, so the corporation proposed…
PLR 200011032: Missing S corporation election allowed with a new Form 2553
A corporation's sole shareholder intended S corporation treatment from its first tax year and relied on an accountant to file Form 2553. The accountant believed it was timely filed, but the IRS had…
PLR 200011031: Foreign insurer's holding company and transfer agent need not report certain share payments
A foreign mutual insurer's demutualization would give policyholders shares in a foreign holding company. This supplemental ruling considered later sales by shareholders who kept their shares and…
PLR 200011030: Corporate shareholder after merger caused an inadvertent S election termination
An S corporation merged with another corporation and acquired a C corporation as a shareholder. That shareholder was ineligible to own S corporation stock, so the S election terminated on the merger…
PLR 200011029: Late S corporation election effective from incorporation date
A corporation's shareholder intended S corporation treatment from its incorporation date, but the election was not filed on time. The IRS found reasonable cause for the delay under section…
PLR 200011028: Late S corporation election granted 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 delay under section 1362(b)(5). It…
PLR 200011027: Late S corporation election effective from incorporation date
A corporation's shareholder intended S corporation treatment from its incorporation date, but the election was not filed on time. The IRS found reasonable cause for the delay under section…
PLR 200011026: Late S corporation election granted 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 delay under section 1362(b)(5). It…
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.