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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County deferred compensation plan qualifies under Section 457(b)
A county adopted a deferred compensation plan for its employees and beneficiaries and requested confirmation that it qualified under IRC § 457(b). The plan included automatic enrollment, elective Roth…
IRS approves a township's governmental deferred compensation plan
A township adopted a nonqualified deferred compensation plan and related trust for its employees and beneficiaries. The plan included salary deferrals, designated Roth contributions, statutory catch-u…
IRS rules a gas-station chain's fair-value hedge accounting on gasoline inventory does not break the LIFO conformity rule
An S corporation that runs convenience stores and gas stations values its inventory (food, beverages, and gasoline) using the last-in, first-out (LIFO) method for both tax and financial reporting. To …
Government-beneficiary settlement trust is a QSF with income excluded under § 115
A statutory trust was set up under a court-approved bankruptcy plan to resolve mass claims (public nuisance, consumer-protection, fraud, and similar claims) against companies over a product tied to a …
9100 relief denied for a late § 475(f) mark-to-market election (hindsight; § 481(a) prejudice)
A C corporation put part of its cash into securities trading, run by its CEO. A trader in securities can elect "mark-to-market" accounting under § 475(f)(1), which treats the securities as sold at yea…
Revised two-step cost-allocation key is a more reliable 1.482-9 method, so the taxpayer's section 482 setoff claim should be accepted
A company that performs shared services for its affiliated corporate group priced those intercompany services for two tax years using the comparable profits method with a markup on costs. During an IR…
IRS rules on nuclear decommissioning trust transfers in a partial sale of a nuclear power plant
Two owners of a nuclear power plant restructured their stakes. A private seller (a disregarded subsidiary of a taxable parent) is selling part of its undivided ownership interest in the plant to a buy…
Consent for a cost-sharing arrangement to switch to the elective method for valuing stock-based compensation
When a U.S. company and its foreign subsidiary share the cost of developing intangibles under a cost sharing arrangement (CSA), the transfer pricing rules require them to include the cost of stock-bas…
60-day extension to elect out of bonus depreciation on 7-year and 15-year property
A partnership (an LLC taxed as a partnership) bought property it classified as 7-year and 15-year property and claimed the extra "bonus" first-year depreciation deduction under section 168(k) on its t…
A utility gets more time to withdraw an overfunded nuclear-decommissioning contribution, plus an approved revised schedule of deductible funding amounts
An investor-owned electric utility owns part of a nuclear power plant and funds its eventual teardown through a Section 468A "qualified nuclear decommissioning fund," which lets it deduct contribution…
A utility gets more time to withdraw an overfunded nuclear-decommissioning contribution, plus an approved revised schedule of deductible funding amounts
An investor-owned electric utility owns part of a nuclear power plant and funds its eventual teardown through a Section 468A "qualified nuclear decommissioning fund," which lets it deduct contribution…
A utility gets more time to pull an overfunded contribution out of its nuclear decommissioning fund, and a revised schedule of deductible funding amounts
An investor-owned electric utility owns part of a nuclear power plant and sets aside money in a special "qualified nuclear decommissioning fund" under Section 468A, which lets it deduct contributions …
IRS rules a nuclear plant acquisition transfers the decommissioning trust funds tax-free with carryover basis under Section 468A
A company acquired the corporate owner of four nuclear power plants, and with them the qualified nuclear decommissioning funds set aside to pay for eventually dismantling those plants. Section 468A an…
IRS approves a utility's revised schedule of ruling amounts for a nuclear decommissioning fund under Section 468A
A public utility that co-owns a nuclear generating unit set aside money in a nuclear decommissioning fund, the reserve used to pay for eventually dismantling the plant. Section 468A lets a utility ded…
IRS approves a revised schedule of nuclear decommissioning fund contributions under § 468A
A public utility that owns part of a nuclear power plant set aside money each year in a special fund to pay for eventually decommissioning (safely dismantling) the plant. Under IRC § 468A, a utility c…
IRS approved a utility's revised schedule for nuclear decommissioning fund contributions
A regulated electric utility asked the IRS to conduct the mandatory review of its revised schedule of annual contributions to a qualified nuclear decommissioning fund. The utility owned a redacted per…
IRS approves a utility's revised nuclear decommissioning funding schedule
A public utility asked the IRS to approve a revised schedule of deductible payments to its nuclear decommissioning reserve fund. The utility owns a redacted percentage of a nuclear plant, and two publ…
Partnership receives 60 days to file late Qualified Opportunity Fund certification
A partnership was formed to operate as a Qualified Opportunity Fund and invest in qualified opportunity zone property. Its first accountant timely filed the partnership return but omitted Form 8996, w…
Participant change did not materially change cost-sharing scope
Chief Counsel considered whether changing one or more controlled participants in a cost-sharing arrangement caused a material change in its scope under Treasury Regulation § 1.482-7(m)(3). The regulat…
IRS approves revised nuclear decommissioning fund contribution schedule
A utility that owns a qualifying interest in a nuclear power plant requested a revised schedule of deductible contributions to its nuclear decommissioning reserve fund. The request used public utility…
Late Form 1128 will be treated as timely filed
A taxpayer filed Form 1128 to request a change in its annual accounting period but missed the filing deadline for the short tax year. It submitted both the form and a request for discretionary relief …
Taxpayer obtains timely-filing relief for Form 1128
A taxpayer sought to change its annual accounting period but filed Form 1128 after the deadline for the required short-period return. The taxpayer submitted the form and its request for discretionary …
IRS accepts late Form 1128 for processing
A taxpayer missed the deadline for filing Form 1128 to request a change in its annual accounting period. It filed the form and requested discretionary administrative relief within 90 days after the de…
Form 1128 receives discretionary late-filing relief
A taxpayer requested permission to change its annual accounting period but did not file Form 1128 by the deadline for the short tax year. It submitted the application and a request for discretionary r…
Missed Form 1128 deadline receives filing relief
A taxpayer filed Form 1128 after the deadline for requesting a change in its annual accounting period. The taxpayer also sought discretionary relief within 90 days of the missed due date. The IRS dete…
Late accounting-period application is deemed timely
A taxpayer missed the filing deadline for Form 1128, which requested a change in its annual accounting period. The taxpayer filed the form and its request for discretionary relief within 90 days after…
Taxpayer may proceed with a late-filed Form 1128
A taxpayer seeking to change its annual accounting period failed to submit Form 1128 by the deadline for the short-period return. It filed the application and requested discretionary relief within the…
IRS waives Form 1128 filing deadline
A taxpayer applied to change its annual accounting period but filed Form 1128 after the applicable deadline. The application and request for discretionary relief arrived within 90 days after the misse…
Revised nuclear decommissioning fund schedule is approved
A utility with a direct ownership interest in a nuclear power plant requested a revised schedule of deductible payments to its nuclear decommissioning fund. The proposed schedule followed public utili…
Mineral royalties qualify as trade-or-business income for passive-loss and net-investment-income rules
A partnership that owns, operates, and manages oil, gas, and other mineral interests asked how its royalties and disposition gains should be treated under the passive-activity and net-investment-incom…
State deferred compensation plan qualifies under section 457(b)
A state adopted a nonqualified deferred compensation plan and related trust for its employees and their beneficiaries. The plan limited deferrals, permitted statutory catch-up contributions, restricte…
Nuclear decommissioning fund received withdrawal relief and revised funding schedules
An energy company acquired interests in a two-unit nuclear facility and related qualified decommissioning funds. Contributions continued automatically after the prior schedules of ruling amounts expir…
QSF need not withhold on principal repayments to foreign claimants
A court-appointed receivership qualified as a settlement fund after the SEC sued an internet-advertising company and its owner for operating a Ponzi scheme. The court-approved claims process allowed v…
Corporation received extra time to request tax-year change
A corporate parent wanted to align its federal tax year with a new financial reporting year. Its accounting firm agreed to prepare the short-period filings, but internal miscommunications between two …
Revised nuclear decommissioning fund contribution schedule approved
A regulated utility requested approval of a revised schedule of deductible contributions to its nuclear decommissioning reserve fund. The schedule used the utility's ownership share, a decommissioning…
IRS approves a revised schedule of ruling amounts for a nuclear decommissioning fund after the plant's license was extended
The taxpayer is a regulated public utility that owns a partial interest in a nuclear power plant. Under Section 468A, a utility can take a current tax deduction for money it sets aside in a special fu…
IRS approves a revised schedule of ruling amounts for a nuclear decommissioning fund after the plant's license was extended
The taxpayer is a regulated public utility that owns a partial interest in a nuclear power plant. Under Section 468A, a utility can take a current tax deduction for money it sets aside in a special fu…
IRS approves a revised schedule of ruling amounts for a nuclear decommissioning fund after the plant's license was extended
The taxpayer is a regulated public utility that owns a partial interest in a nuclear power plant. Under Section 468A, a utility can take a current tax deduction for money it sets aside in a special fu…
Nuclear facility sale qualifies as an applicable asset acquisition
A seller proposed transferring a shut-down nuclear facility, related assets, and a decommissioning trust to a purchaser that would assume the nuclear decommissioning liability. The purchaser would bec…
Nuclear facility sale qualifies as an applicable asset acquisition
A seller proposed transferring a shut-down nuclear facility, related assets, and a decommissioning trust to a purchaser that would assume the nuclear decommissioning liability. The purchaser would bec…
Nuclear decommissioning fund schedule of ruling amounts approved
A regulated utility requested a schedule of annual ruling amounts for deductible contributions to a nuclear decommissioning fund covering its ownership share of a nuclear plant. The schedule used deco…
Court-approved settlement trust qualifies as a qualified settlement fund
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Court-approved settlement trust qualifies as a qualified settlement fund
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Court-approved settlement trust qualifies as a qualified settlement fund
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Settlement trust qualifies once all qualified fund requirements are met
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Settlement trust qualifies once all qualified fund requirements are met
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Court-approved settlement trust qualifies as a qualified settlement fund
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Court-approved settlement trust qualifies as a qualified settlement fund
A court approved a statutory trust to help resolve product-related claims against manufacturers and distributors. The trust receives a stated share of settlement payments through a separate administra…
Revised nuclear decommissioning fund contribution schedule approved
A utility subsidiary that owned a qualifying interest in a nuclear plant requested a mandatory revised schedule of deductible payments to its nuclear decommissioning reserve fund. The requested schedu…
Statutory product-liability escrows qualify as settlement funds and deposits are deductible
A manufacturer that was not a defendant in product litigation was required by multiple jurisdictions to deposit amounts into escrow accounts based on its sales of the redacted product. The accounts co…
Nuclear decommissioning fund special transfer schedule approved
A corporate group that owns an unregulated nuclear power unit requested an initial schedule of deduction amounts for a special transfer to its qualified nuclear decommissioning fund. The taxpayer supp…
Nuclear decommissioning fund ruling amount schedule approved
A corporate energy group requested a schedule of ruling amounts for the qualified nuclear decommissioning fund associated with an unregulated nuclear power plant. The request used a decommissioning st…
A parent partnership computes its section 7519 required payment using only the subsidiary income allocated to it
A partnership uses a fiscal year rather than the calendar year it would otherwise be required to use, under a section 444 election. That election lets a partnership keep a non-calendar tax year (and t…
Revised nuclear decommissioning funding schedule approved
An investor-owned electric utility requested a revised schedule of ruling amounts for the qualified fund used to pay for decommissioning its nuclear plant. The plant's operating license had been exten…
IRS approved an initial nuclear decommissioning fund contribution schedule
A utility with a qualifying ownership interest in a nuclear power plant requested an initial schedule of deductible contributions to its nuclear decommissioning fund under Section 468A. The proposed s…
Taxpayer was denied extra time to request an accounting-period change
A taxpayer asked for extra time to file Form 1128 to change its annual accounting period. The request came more than 90 days after the form's due date. The IRS concluded that the taxpayer had not show…
Taxpayer was denied extra time to request an accounting-period change
A taxpayer asked for extra time to file Form 1128 to change its annual accounting period. The request came more than 90 days after the form's due date. The IRS concluded that the taxpayer had not show…
Taxpayer was denied extra time to request an accounting-period change
A taxpayer asked for extra time to file Form 1128 to change its annual accounting period. The request came more than 90 days after the form's due date. The IRS concluded that the taxpayer had not show…
Taxpayer is denied extra time to file Form 1128 for an accounting-period change
A taxpayer asked for an extension to file Form 1128 and change its annual accounting period under IRC § 442. The application was due with the short-period return, but the taxpayer did not seek late-el…
Taxpayer is denied extra time to file Form 1128 for an accounting-period change
A taxpayer asked for an extension to file Form 1128 and change its annual accounting period under IRC § 442. The application was due with the short-period return, but the taxpayer did not seek late-el…
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.