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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Insolvent bank may protect depositor assets from tax unrelated to federal assistance
An insolvent bank received federal financial assistance during a receivership transaction and separately reported taxable income from a litigation recovery. The tax liability came entirely from the li…
Revenue officer may use and share a credit report for hardship review
The Taxpayer Advocate Service asked Field Collection to determine whether a taxpayer faced enough financial hardship for currently-not-collectible status. Chief Counsel advised that the revenue office…
Medicaid contractor status depends on insurance risk and beneficiary rights
Chief Counsel addressed when entities providing Medicaid services are health insurance issuers and covered health insurance providers for the compensation deduction limit in section 162(m)(6). A non-r…
Cooperative's preferred-stock exchange avoids deemed distribution
A non-stock cooperative proposed a mandatory exchange of newly issued publicly traded preferred stock for patrons' qualified written notices of allocation. Participation would be limited by recent bus…
Life insurer may deduct partnership investment fees
Chief Counsel addressed how a life insurer should calculate its share of dividends-received deductions for separate-account assets invested through partnerships. The insurer includes its distributive …
Cooperative grain venture preserves patronage treatment and production deduction rules
A nonexempt agricultural cooperative planned to combine its grain marketing operations with another cooperative and a corporate investor through an LLC taxed as a partnership. The cooperative would co…
Corporate group may switch to tax book value for interest allocation
A domestic corporate group had long used fair market value to value assets when apportioning interest expense. It asked to switch because that method required significant professional fees and employe…
Acquired group may switch to tax book value for interest allocation
A domestic corporate group had used fair market value to apportion interest expense because a former parent required that method. After later ownership changes, the group asked to use tax book value t…
Acquiring group may retain tax book value for interest allocation
A domestic consolidated group had long used tax book value to apportion interest expense. It acquired another group that had used fair market value, which otherwise required the combined related group…
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.