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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IRS rules a combined universal-life policy and its annuity rider are separate contracts for tax purposes
A life insurance company plans to sell a single product that bundles a universal life insurance policy (the "Base Contract") with a single-premium immediate annuity attached as a rider (the "Annuity…
IRS rules a combined universal-life policy and its annuity rider are separate contracts for tax purposes
A life insurance company plans to sell a single product that bundles a universal life insurance policy (the "Base Contract") with a single-premium immediate annuity attached as a rider (the "Annuity…
Line-of-duty disability and death benefits received specified income-tax exclusions
A state governmental retirement plan asked about special benefits for public safety officers who are permanently disabled, catastrophically injured, or killed in the line of duty. The disability…
Intragroup life-policy transfers preserved death-benefit exclusion
A consolidated corporate group planned to move pools of employee life insurance policies through several wholly owned subsidiaries. The first contribution would exchange the policies for cash below…
Court-ordered restructuring of long-term care policies in an insurer rehabilitation is not a taxable event for policyholders
A state-domiciled life insurance company that sold guaranteed-renewable long-term care policies was placed into rehabilitation by a state court because its projected liabilities far exceeded its…
IRS preserves life-insurance exclusion in intragroup policy transfers
A corporate parent owned life-insurance policies on employees and former employees, most with built-in gain. It proposed contributing the policies through three tiers of wholly owned subsidiaries in…
Assumption reinsurance would not restart life insurance tax tests
Members of a corporate group owned private-placement variable life insurance policies on selected employees to finance employee benefit liabilities. After an event involving the insurer, the…
Long-term care premium refund death benefit met contract rules
A life insurance company offered group long-term care coverage with a premium stabilization feature. The feature could use a calculated amount to offset future premiums or, when the insured died,…
Court-approved restructuring of an insolvent long-term-care insurer's policies is tax-neutral to policyholders
Two affiliated life insurance companies that sold long-term care policies became insolvent and were placed into court-supervised liquidation, and a state court approved a plan to restructure their…
Assumption reinsurance did not materially change an employer-owned life insurance policy
A policyholder held a group flexible-premium variable life insurance policy covering directors and highly compensated employees or individuals. The issuing insurer proposed to transfer the policy to…
Insurer merger does not restart life policy tax tests
Two affiliated life insurance companies planned to merge, with one company surviving and assuming the other's policies. The policy terms would not change, and the surviving company would not issue…
Assumption reinsurance preserves life policy tax status
A holding company planned to transfer life insurance contracts from two subsidiaries to an unrelated insurer through assumption reinsurance as it exited the life insurance business. The new insurer…
Trust's life insurance purchase avoided the transfer-for-value rule
Several grantor trusts owned interests in life insurance policies on a married couple, and another grantor trust proposed buying those interests. One spouse was treated as an owner of both the…
Life insurance transfer between grantor trusts avoided the transfer-for-value rule
A married couple owned a grantor trust holding life insurance policies on their joint lives and on one spouse. A separate grantor trust owned by the other spouse proposed to buy the policies so that…
PLR 1330016 approves a direct annuity contract exchange after the owner's death
The IRS rules that a beneficiary may directly transfer the value of five annuity contracts inherited from the beneficiary's mother to a new annuity contract without recognition under IRC §…
PLR 1308019: IRS approves tax treatment for banks contributing life-insurance policies to a partnership
The IRS considered a plan in which banks would contribute permanent, cash-value life-insurance policies to a partnership in exchange for partnership interests. The IRS ruled that the contributions…
PLR 1304003: IRS approves a post-death exchange of life insurance policies under § 1035
After one insured under a survivorship life insurance policy died, a trust exchanged the policy for a new policy covering only the surviving insured. The IRS ruled that the trust did not have to…
Trust and life insurance rulings for an irrevocable trust
A taxpayer requested rulings on two irrevocable trusts, including a trust that would acquire a life insurance policy from another trust. The IRS addressed grantor trust treatment, beneficiary…
PLR 1230009: IRS treats a requested life insurance benefit reduction as a new issuance
The IRS ruled that reducing the face amount of certain life insurance contracts at an owner’s request would be treated as an exchange that makes the contracts newly issued for…
PLR 1217017: IRS approves employer-owned life insurance coverage after reviewing notice and consent documents
An employee-owned corporation asked whether its corporate-owned life insurance contracts met the notice and consent requirements of IRC section 101(j)(4). The corporation had not obtained a separate…
PLR 1213016: Long-term-care rider qualifies as insurance and benefits are excludable
The IRS ruled that a noncancellable long-term-care rider attached to certain annuity contracts was an insurance contract under IRC § 7702B(b)(1). The rider reimbursed qualifying long-term-care…
PLR 1152014: IRS addresses a partnership transfer of bank-owned life insurance policies
The IRS ruled on a proposed transaction in which two banks would transfer certain bank-owned life insurance policies to a partnership in exchange for partnership interests. The transfer would not be…
PLR 1137008: IRS allows reasonable expense charges in a life insurance policy's deemed cash surrender value
A stock life insurance company asked whether reasonable expense charges could be taken into account when calculating a universal life insurance policy's deemed cash surrender value for the section…
PLR 1105027: Wellness rider does not disqualify qualified long-term care insurance
The IRS considered a life insurance company’s proposed wellness rider for qualified long-term care insurance contracts. The rider would provide health and long-term-care information and could offer…
PLR 1105026: Wellness rider does not disqualify qualified long-term care insurance
The IRS considered a life insurance company’s proposed wellness rider for qualified long-term care insurance contracts. The rider would provide health and long-term-care information and could offer…
PLR 1105001: IRS rules that a long-term-care rider is an insurance contract
The IRS considered a life insurance company's proposed rider for fixed and variable annuity contracts that would provide long-term-care benefits when the covered person became chronically ill. 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.