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 1128003: IRS approves revised nuclear decommissioning-fund ruling amounts
A taxpayer that owns and operates part of a nuclear power plant asked the IRS to approve revised annual amounts for funding the plant's nuclear decommissioning reserve. The request followed an…
PLR 1126026: Taxpayers received more time to elect a single rental real estate activity
The IRS granted married taxpayers an extension to make an election treating all of their rental real estate interests as one rental real estate activity. They had filed a joint return without the…
PLR 1126016: Married taxpayers received more time to elect one rental real estate activity
Married taxpayers asked for more time to elect to treat all of their interests in rental real estate as one rental real estate activity. They had qualified to make the election but filed their joint…
PLR 1126011: Settlement trust qualified for tax treatment and related deductions
A publicly traded corporation and related parties planned to resolve disputed tort and contract claims through a court-supervised trust. The IRS ruled that the trust would qualify as a qualified…
PLR 1125002: More time granted to make a rental real estate activity election
The IRS granted a taxpayer 120 more days to elect to treat all interests in rental real estate as a single rental real estate activity. The taxpayer was eligible to make the election but filed its…
Facility fees are deductible when paid under the economic-performance rules
Chief Counsel Advice addressed when a taxpayer may deduct annual facility fees paid to a limited partner that guaranteed the taxpayer's bond. The advice concluded that the fee was not interest and…
PLR 1117011: Extension of time to elect single rental real estate activity
The IRS considered a taxpayer's request to treat all interests in rental real estate as one activity for passive activity purposes. The taxpayer qualified for the real property business exception…
PLR 1117001: Amendments to grandfathered deferred compensation plans do not trigger section 457
The IRS considered proposed amendments to substantially similar deferred compensation plans maintained by a tax-exempt organization. The plans were established before the 1986 changes to section 457…
PLR 1114007: IRS grants 30 days to file a duplicate Form 3115
The IRS granted a taxpayer 30 days to file a signed duplicate Form 3115 after the taxpayer's preparer failed to submit it on time. The form related to a change in inventory valuation from cost to…
CCA 1112010: Passive activity rules limit partners' losses
Chief Counsel advised that section 469 would continue to limit the amount of losses allocated to the partners in the activity. The advice treated the activity as passive and stated that no exception…
PLR 1112002: liquidating trust receives more time to make disputed ownership fund election
The IRS granted a reserve established by a liquidating trust 45 more days to file the statement needed to elect disputed ownership fund treatment. The reserve's trustee had not timely filed the…
CCA 1111013: economic valuation should determine compensation for initial intangible contributions
Chief Counsel advice addressed how to determine compensation when a parent provides a valuable initial service or intangible to a related party that must perform further development before…
CCA 1111006: design costs must be capitalized before future long-term contracts
Chief Counsel advice considered whether design and development costs, including research and experimental costs under section 174, had to be capitalized as pre-contracting year costs. The taxpayer…
PLR 1109008: The IRS granted a liquidating trust more time to elect disputed ownership fund treatment
A reserve within a bankruptcy liquidating trust asked for more time to elect treatment as a disputed ownership fund under Treas. Reg. § 1.468B-9(c)(2)(ii). The election had to be attached to the…
PLR 1109007: The IRS granted a liquidating trust more time to elect disputed ownership fund treatment
A reserve within a bankruptcy liquidating trust asked for more time to elect treatment as a disputed ownership fund under Treas. Reg. § 1.468B-9(c)(2)(ii). The election had to be attached to the…
PLR 1108027: Taxpayer granted more time to elect single rental real estate activity treatment
The IRS granted a taxpayer an extension of time to elect to treat all interests in rental real estate as one rental real estate activity. The taxpayer was in a real property business and qualified…
CCA 1106008: TCAP grants are taxable when received or when the right to receive them is fixed
Chief Counsel advice addressed Tax Credit Assistance Program (TCAP) grants awarded through state housing credit agencies to owners of eligible low-income housing projects. The IRS concluded that the…
PLR 1105016: IRS approves treatment of note repurchase premiums and consent fees
A taxpayer proposed a tender offer to repurchase senior notes and a consent solicitation to amend the related note indentures as part of a business restructuring. The IRS ruled that any amount paid…
PLR 1105005: IRS approves tax treatment of a guaranteed withdrawal annuity certificate
A life insurance company planned to issue a certificate linked to selected assets in a managed account. The certificate would allow withdrawals and provide a guaranteed minimum lifetime benefit if…
CCA 1103052: Counsel addresses advance-payment deferral for hotel and special-function rooms
Chief Counsel advised that, when administering Rev. Proc. 2004-34, section 4.01(3)(d) applies both to hotel rooms used for overnight stays and to special-function rooms such as banquet halls. The…
PLR 1103014: IRS approves a revised nuclear decommissioning reserve funding schedule
A utility that owned an interest in a nuclear power plant requested a revised schedule of ruling amounts for its nuclear decommissioning reserve fund. The request followed a public utility…
PLR 1103002: Existing deferred compensation plans remain outside section 457 if future deferrals are frozen
An organization that was taxable when it established three nonqualified deferred compensation plans expected to become tax-exempt. It asked whether section 457 would apply to the existing plans…
PLR 1102030: IRS approves a revised nuclear decommissioning funding schedule
The taxpayer requested a revised schedule of ruling amounts for contributions to a nuclear decommissioning reserve fund. The IRS concluded that the taxpayer had a qualifying interest in the nuclear…
PLR 1102029: IRS approves a special nuclear decommissioning transfer and deduction schedule
The taxpayer requested an initial schedule of deduction amounts for a special transfer to a nuclear decommissioning fund, together with a revised schedule of ruling amounts. The IRS concluded that…
PLR 1051006: Revised nuclear decommissioning funding schedule approved
A nuclear power plant owner requested a revised schedule of ruling amounts for its qualified nuclear decommissioning reserve fund after the plant's operating license was extended. The IRS concluded…
PLR 1050023: Extension granted for a rental real estate activity election
The IRS granted married taxpayers additional time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were eligible to make the election…
PLR 1050022: Extension granted for a rental real estate activity election
The IRS granted married taxpayers additional time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were eligible to make the election…
PLR 1050010: IRS approved a revised nuclear decommissioning reserve funding schedule
The IRS reviewed a utility's proposed revised schedule of annual amounts to fund a nuclear power plant decommissioning reserve after the plant's operating license was extended. The taxpayer…
PLR 1050009: IRS approved a revised nuclear decommissioning reserve funding schedule
The IRS reviewed a utility's proposed revised schedule of annual amounts to fund a nuclear power plant decommissioning reserve after the plant's operating license was extended. The taxpayer…
PLR 1050007: IRS approved a revised nuclear decommissioning reserve funding schedule
The IRS reviewed a utility's proposed revised schedule of annual amounts to fund a nuclear power plant decommissioning reserve after the plant's operating license was extended. The taxpayer…
PLR 1050004: IRS approved a special transfer and deduction schedule for nuclear decommissioning costs
The IRS reviewed a taxpayer's request to make a special transfer to a qualified nuclear decommissioning fund and deduct that transfer over the plant's remaining useful life. The taxpayer had…
PLR 1050003: IRS approves nuclear decommissioning deduction schedules after an ownership transfer
The taxpayer acquired an ownership interest in a nuclear power plant and its qualified nuclear decommissioning funds from prior owners. It asked for a schedule of deduction amounts for special…
PLR 1049009: Nuclear decommissioning fund schedules are approved
This ruling addresses a utility's requests for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The IRS concluded that…
PLR 1049005: Nuclear decommissioning fund schedules are approved after an ownership transfer
This ruling addresses a taxpayer that acquired an ownership interest in a nuclear power plant and the related qualified decommissioning funds. The IRS approved a schedule of deduction amounts for a…
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.