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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Cash used in acquisition does not defeat active-business rule
A public corporation acquired an unrelated target in a reorganization using its own stock and cash. The target owned a subsidiary that planned to separate three businesses into newly formed controlled…
Church university retirement plans qualify as church plans
A tax-exempt university affiliated with a church requested church-plan status for two retirement plans maintained for its employees. A religious organization was the university's sole member, appointe…
Tribal organization may receive deductible charitable contributions
Federally recognized Indian tribes in one region formed and funded an organization to carry out a shared project. The project promoted economic development, preserved cultural and subsistence resource…
Government insurance trust's income is excluded under Section 115
An association of state political subdivisions operated a trust that provided self-insured property, liability, and workers' compensation pools, along with group medical, dental, and disability insura…
Local-government association's income is excluded and Form 990 waived
An association of state special districts helped its governmental members share information, manage risks and insurance, obtain financial and administrative assistance, and reduce operating costs. Its…
Sixty-day IRA rollover waiver denied for unsupported bank error
An IRA owner withdrew an amount from an IRA and did not return it to an IRA within 60 days. He said he mistakenly believed the withdrawal was required, was not advised by the bank about the tax conseq…
Foundation's grants to artists and teachers approved
A private foundation requested advance approval for a grant program serving artists and teachers in a metropolitan area. Applicants would be evaluated on financial need, prior achievement, motivation,…
Foundation scholarship procedures approved
A private foundation requested advance approval for scholarships supporting needy undergraduate and graduate students in a metropolitan area. Its board would select recipients based on financial need,…
Graduate educational travel grants approved
A private foundation proposed expanding an existing graduate fellowship program to fund educational travel in the United States and abroad. Applicants would submit travel plans and educational goals, …
Artist development grant program approved
A private foundation proposed a program providing artists with grants and industry resources for research, retreats, drafting, workshops, short works, and other professional development. Candidates wo…
Fee-based consulting organization denied charitable exemption
An organization sought exemption as a charity under IRC § 501(c)(3). It substantially provided consulting and administrative services for fees at or above cost. The IRS found that the organization had…
IRS may consider an informal abatement request after the assessment period expires
Chief Counsel advised that the IRS may consider new information submitted as an informal request to abate an income, estate, or gift tax assessment even though IRC § 6404(b) does not give taxpayers a …
IRS office may use an unredacted private letter ruling
Chief Counsel advised that the relevant IRS office should have an unredacted copy of a private letter ruling available for use in addressing a question about self-created goodwill. If that office had …
IRS employees may receive unredacted ruling for tax administration
Chief Counsel advised that IRC § 6103(h)(1) permitted disclosure of an unredacted private letter ruling to a Treasury attorney and revenue agent who needed it for tax administration. The requester sho…
Levy does not reach contract payments that are not yet due
Chief Counsel confirmed the position stated in CCA 199930003 and agreed that the government should concede the issue in the pending case. The levy did not reach payments that a third party might make …
Employment tax employer regulations identified for review
Following an employment tax discussion, Chief Counsel provided temporary regulations under IRC § 3501 and Announcement 85-113. It also identified portions of the regulations defining an employer under…
Credit election moved after assessment period was not covered by revenue ruling
Chief Counsel advised that Rev. Rul. 85-67 did not apply when a credit election was not transferred to the following tax year, which had an unassessed liability, until after the assessment statute exp…
Amount realized defines stock value under the unified loss rule
A consolidated group sold loss-share subsidiary stock for an amount far below a valuation estimate and claimed the resulting stock loss. Chief Counsel concluded that the unified loss rule required the…
Foreign parent's non-LIFO reporting satisfies conformity requirement
A domestic subsidiary used LIFO for most inventory while its foreign parent considered adopting IFRS, which would report the subsidiary's results on a non-LIFO basis. The foreign parent and its financ…
Extension granted for depreciation elections after adviser error
A corporation relied on an outside return preparer who failed to analyze an ownership change and its limits on net operating losses. The corporation consequently missed elections to forgo bonus deprec…
Revised nuclear decommissioning fund schedule approved
A regulated public utility requested a revised schedule of deductible contributions to its nuclear decommissioning fund after shutting down a plant and beginning decommissioning. The proposed schedule…
Revised decommissioning schedule approved after rate reduction
A public utility requested a revised schedule of contributions to its nuclear decommissioning fund after its regulator reduced the decommissioning costs included in rates. The reduction meant that pri…
Nuclear fund schedule revised after regulated costs declined
A public utility requested a revised schedule of contributions to its nuclear decommissioning fund after its regulator reduced the decommissioning costs included in rates. The reduction meant that pri…
Extension granted to amortize research expenditures
An affiliated corporate group intended to elect ten-year ratable deductions for research and experimental expenditures but did not make the election with its timely consolidated return. The group repr…
Pension funding excise tax conditionally waived
A company's financial condition had deteriorated, it could no longer contribute to its pension plan, and it was pursuing a distress termination through the Pension Benefit Guaranty Corporation. The IR…
Late QSST election receives inadvertent S termination relief
After the owner of a grantor trust died, the trust continued holding S corporation shares for a beneficiary but did not timely elect qualified subchapter S trust status. That failure terminated the co…
IRS denies waiver for missed plan-loan rollover deadline
A former employee's retirement-plan loan went into default after automatic bank transfers stopped, causing the unpaid balance to be treated as a distribution. She sought a waiver of the 60-day rollove…
Mental incapacity supports late retirement rollover relief
A 75-year-old retiree received distributions from two qualified plans that were deposited in a nonretirement savings account. She missed the 60-day rollover deadline while experiencing physical and co…
Dental scholarship procedures approved
A private foundation requested advance approval for scholarships supporting students in dental assistant training and other dental professions. Applicants would be evaluated using financial need, inte…
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.