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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Administrative delay did not make pension buyout an accelerated payment
A governmental retirement system offered eligible members a lump sum in exchange for reduced future cost-of-living increases. Members elected the buyout with their retirement applications, but adminis…
Sole-heir spouse could roll an estate-received IRA into his own IRA
A decedent's IRA named no beneficiary, so its balance was payable to the estate. The surviving spouse was both the estate's sole heir and its sole administrator. The IRS treated the spouse as the paye…
Two pension plans received substitute mortality table approval
A taxpayer requested substitute mortality tables for two pension plans. The request covered aggregated male and female annuitants and nonannuitants, but excluded disabled participants. The IRS approve…
Salaried pension plan received substitute mortality table approval
A taxpayer requested substitute mortality tables for male and female annuitants in a salaried pension plan, including disabled participants. The plan's nonannuitant population lacked credible mortalit…
Four pension plans received substitute mortality table approval
A taxpayer requested substitute mortality tables for the combined male and female annuitant and nonannuitant populations of four pension plans, including disabled participants. A fifth plan lacked cre…
Hourly pension plan received substitute mortality table approval
A taxpayer requested substitute mortality tables for all male and female annuitant and nonannuitant populations in an hourly pension plan, including disabled participants. A separate ruling would addr…
Pension plan received substitute annuitant mortality table approval
A taxpayer requested plan-specific substitute mortality tables for the male and female annuitants of one pension plan, including disabled participants. The IRS approved the tables for ten plan years a…
Two pension plans received substitute annuitant mortality table approval
A taxpayer requested aggregated substitute mortality tables for the male and female annuitants of two pension plans, including disabled participants. The IRS approved the tables for ten plan years aft…
Pension plan received five-year substitute mortality table approval
A taxpayer requested substitute mortality tables for the male and female annuitants of one pension plan. The IRS approved the tables for five plan years, excluding disabled participants, after finding…
Four pension plans received conditional substitute mortality table approval
A taxpayer requested aggregated substitute mortality tables for the male and female annuitant and nonannuitant populations of four pension plans, including disabled participants. The IRS approved the …
Five pension plans received conditional participant mortality tables
A taxpayer requested combined substitute mortality tables for the male and female participants of five pension plans, including disabled participants. The IRS approved the tables for ten plan years af…
Six pension plans received substitute mortality table approval
An employer requested substitute mortality tables for six pension plans covering male and female union and nonunion participants, including disabled participants. The IRS approved the four combined po…
Four pension plans received annuitant mortality table approval
An employer requested substitute mortality tables for the combined male and female annuitant populations, including disabled participants, of four pension plans. The IRS approved the tables for ten pl…
Two pension plans received substitute mortality table approval
An employer requested substitute mortality tables for two pension plans' combined annuitant and nonannuitant populations, excluding disabled participants. The IRS approved the tables for ten plan year…
Cash-balance amendment preserves cooperative plan's CSEC status
A tax-exempt association sponsored a multiple-employer defined benefit plan maintained primarily by rural cooperatives and treated as a CSEC plan. It proposed adding a cash-balance formula that adopti…
Estate may divide IRA into inherited IRAs for two children
A decedent named the estate as beneficiary of an IRA, while the estate passed through a trust in equal shares to two children. The estate wanted to divide the IRA in kind through trustee-to-trustee tr…
VEBA surplus may fund current employee medical benefits
An employer maintained two voluntary employees' beneficiary association trusts holding assets for retiree medical benefits, one for non-bargaining employees and one for bargaining employees. Both trus…
Two pension plans may use substitute annuitant mortality tables
A taxpayer requested substitute mortality tables for two pension plans treated as a combined group. The IRS approved plan-specific tables for male and female annuitants other than disabled participant…
Four union pension plans may use substitute mortality tables
A taxpayer requested substitute mortality tables for four union pension plans aggregated as one included group. The IRS approved tables for male and female annuitants and nonannuitants, excluding disa…
Two pension plans may use substitute annuitant mortality tables
A taxpayer requested substitute mortality tables for two pension plans treated as a combined group. The IRS approved plan-specific tables for male and female annuitants other than disabled participant…
Substitute mortality tables approved for eight plans
A controlled group requested permission to use substitute mortality tables for eight aggregated pension plans. The request covered male and female annuitants and nonannuitants, including disabled part…
Pension plan substitute mortality tables approved
A pension plan requested permission to use substitute mortality tables for its male and female annuitants and nonannuitants, including disabled participants. The IRS found that the submitted rates wer…
IRA divided for four trust beneficiaries using eldest child's life expectancy
A decedent named a revocable trust as beneficiary of an IRA, and the trust became irrevocable at death for the benefit of the decedent's four children. The trustees proposed direct trustee-to-trustee …
Surviving spouse is sole Roth IRA beneficiary for RMD purposes
A decedent named a marital trust as beneficiary of a Roth IRA after dying past his required beginning date. Under the trust's original terms, retirement-plan withdrawals had to be paid outright to the…
Spouse may roll inherited IRA proceeds from her revocable trust
A decedent named his spouse's revocable trust as beneficiary of his IRA. The spouse was the trust's sole trustee and beneficiary, could withdraw all trust income and principal, and had sole authority …
Multiemployer plan receives amortization extensions
A multiemployer pension plan requested automatic extensions for amortizing numerous unfunded-liability bases arising from plan amendments, actuarial losses, and assumption changes. The IRS approved ex…
Pension plan may use substitute mortality tables for annuitants
A controlled group requested substitute mortality tables for several defined benefit plans. The IRS approved Plan IF's tables for male and female annuitants, including disabled participants, for 10 pl…
Pension plan may use substitute mortality tables for annuitants
A controlled group requested substitute mortality tables for several defined benefit plans. The IRS approved Plan TM's tables for male and female annuitants, including disabled participants, beginning…
Pension plan may use substitute mortality tables for all participant groups
A controlled group requested substitute mortality tables for several defined benefit plans. The IRS approved Plan IO's tables for male and female annuitants and nonannuitants, including disabled parti…
Two pension plans may use substitute mortality tables for four populations
A controlled group requested substitute mortality tables for two defined benefit plans. The IRS approved combined tables for male and female annuitants and nonannuitants in those plans, excluding disa…
Letting employees borrow to buy shares does not disqualify an employee stock purchase plan
An employee stock purchase plan (ESPP) that qualifies under section 423 gives employees favorable tax treatment: no income at the time they buy discounted employer stock, with tax deferred until they …
Splitting a decedent's IRA (left to his estate) into separate inherited IRAs for the heirs is not a taxable distribution
A man died after he had started taking required minimum distributions (RMDs) from his IRA, and he had named his estate (not a person) as the account's beneficiary. His will left the estate's interest …
Substitute mortality tables approved for a defined benefit pension plan under § 430(h)(3)
Employers that sponsor single-employer defined benefit pension plans must calculate their minimum funding obligations under Internal Revenue Code § 430 using mortality tables (assumptions about how lo…
Pension plan may use substitute mortality tables for all participant populations
A defined benefit pension plan asked to use substitute mortality tables for its male and female annuitants and nonannuitants, including disabled participants. The IRS approved the tables for 10 plan y…
Aggregated pension plans may use substitute mortality tables for annuitants
A taxpayer requested substitute mortality tables for the combined male and female annuitants of three pension plans. The IRS approved the tables, including their application to disabled participants, …
Eight pension plans received substitute mortality-table approval
A controlled group asked to use substitute mortality tables for the combined male and female annuitants, including disabled participants, in eight defined benefit pension plans. The IRS approved the t…
Pension plan received conditional substitute mortality-table approval
A pension plan requested substitute mortality tables for four participant populations. The IRS approved tables for male annuitants, female annuitants, and male nonannuitants for ten plan years, but re…
Three pension plans received combined substitute mortality tables
A controlled group requested substitute mortality tables for participants in three defined benefit pension plans. The IRS approved combined male and combined female tables covering annuitants and nona…
Three plans received combined mortality tables including disabled participants
A controlled group requested substitute mortality tables for three defined benefit pension plans. The IRS approved combined male and combined female tables covering annuitants and nonannuitants, inclu…
Two pension plans received combined substitute mortality tables
A taxpayer requested permission to use substitute mortality tables for two defined benefit pension plans. The IRS approved combined male and combined female tables for annuitants and nonannuitants, ex…
Pension plan received substitute mortality tables for annuitants
A pension plan requested substitute mortality tables for its participant populations. The IRS approved male and female annuitant tables, including disabled participants, for ten plan years. Male and f…
Pension plan received conditional substitute mortality-table approval
A pension plan requested substitute mortality tables for all male and female participants, including disabled participants. The IRS conditionally approved the tables for ten plan years. Because the co…
Pension plan received substitute mortality tables for annuitants
A pension plan requested substitute mortality tables for its participant populations. The IRS approved tables for male and female annuitants, including disabled participants, for ten plan years. Male …
Pension plan received substitute mortality tables for annuitants
A pension plan requested substitute mortality tables for an included group of participants. The IRS approved tables for male and female annuitants, including disabled participants, for ten plan years.…
Pension plan received substitute mortality tables for all populations
A pension plan requested substitute mortality tables for its participant populations. The IRS approved tables for male and female annuitants and nonannuitants, including disabled participants, for ten…
Two pension plans received substitute mortality tables for annuitants
A taxpayer requested substitute mortality tables for two pension plans treated on an aggregated basis. The IRS approved tables for male and female annuitants, excluding disabled participants, for ten …
Surviving spouse may roll over an IRA after other beneficiaries disclaim it
A decedent named a trust as the sole beneficiary of an IRA and did not name a contingent beneficiary. Within nine months of death, the trust, the decedent's son, and two grandchildren disclaimed their…
Pension plan approved to use substitute mortality tables, but subject to yearly actuarial recertification
Single-employer defined benefit pension plans value their liabilities using mortality tables, and a plan with enough of its own credible mortality experience can ask the IRS to approve "substitute" ta…
Two pension plans approved to use substitute mortality tables, with limits for disabled participants
Single-employer defined benefit pension plans value their liabilities using mortality tables, and a plan with enough of its own credible mortality experience can ask the IRS to approve "substitute" ta…
Pension plan approved to use substitute mortality tables for its participants
Single-employer defined benefit pension plans must value their liabilities using mortality tables, and a plan with enough of its own credible mortality experience can ask the IRS to approve "substitut…
Two pension plans may use substitute mortality tables for annuitants
A pension plan sponsor asked to use plan-specific substitute mortality tables for two plans when computing minimum funding under IRC § 430. The IRS approved the tables for the plans' aggregated male a…
Surviving spouse is treated as IRA beneficiary through a conduit trust
An IRA owner died after required minimum distributions had begun and had named a revocable trust as the IRA beneficiary. At death the trust became irrevocable, and its subtrust required every retireme…
IRS approves an employer's substitute mortality tables for pension funding for 10 plan years
Employers that sponsor traditional (defined benefit) pension plans must calculate their required annual funding using mortality tables, which predict how long retirees will live and therefore how much…
Acquired company qualifies for separate-line-of-business administrative scrutiny
A taxpayer acquired a specialized company that continued to operate autonomously with its own leadership, board, finances, human resources, payroll, offices, technology, customers, and employee benefi…
Executor gets an IRA rollover waiver after the account owner's cognitive decline
An IRA owner withdrew cash while experiencing severe cognitive impairment and did not roll it over within 60 days. Medical evidence showed a persistent decline, and the owner's son was later appointed…
Multiemployer plan receives five-year extensions for unfunded-liability amortization
A multiemployer pension plan requested more time to amortize unfunded liabilities arising from plan amendments, actuarial losses, and actuarial assumption changes. The plan's actuary certified that wi…
Two plans may use substitute mortality tables for annuitants but not nonannuitants
A taxpayer requested permission for two defined benefit pension plans to use plan-specific substitute mortality tables. The IRS approved substitute rates for the plans' combined male and female annuit…
Seven pension plans may use combined substitute mortality tables for 10 years
A taxpayer requested permission for seven defined benefit pension plans to use plan-specific substitute mortality tables. The proposed tables combine the plans' male participants into one population a…
Plan may use substitute mortality tables for three populations but not a fourth
A defined benefit pension plan asked to use plan-specific substitute mortality tables for up to 10 plan years. The IRS approved substitute rates for union men, non-union men, and female annuitants. It…
Multiemployer plan receives five-year extensions for unfunded-liability amortization
A multiemployer pension plan requested more time to amortize a series of unfunded-liability charge bases. The plan's actuary certified that without relief the plan would face an accumulated funding de…
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.