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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Corporate conversion preserves qualified small business stock status
A corporation sold and redeemed portions of its original shareholders' stock, then converted under state law into a limited liability company that remained taxed as a corporation. The taxpayer represe…
Corporate conversion preserves qualified small business stock status
A corporation sold and redeemed portions of its original shareholders' stock, then converted under state law into a limited liability company that remained taxed as a corporation. The taxpayer represe…
Corporate conversion preserves qualified small business stock status
A corporation sold and redeemed portions of its original shareholders' stock, then converted under state law into a limited liability company that remained taxed as a corporation. The taxpayer represe…
Related-party aircraft qualify as held for productive business use
A partnership exchanged aircraft that it owned and leased to a related operating business whose executives used them for business and personal travel. The leases covered carrying costs but were not 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.