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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IRS rules a combined universal-life policy and its annuity rider are separate contracts for tax purposes
A life insurance company plans to sell a single product that bundles a universal life insurance policy (the "Base Contract") with a single-premium immediate annuity attached as a rider (the "Annuity R…
IRS rules a combined universal-life policy and its annuity rider are separate contracts for tax purposes
A life insurance company plans to sell a single product that bundles a universal life insurance policy (the "Base Contract") with a single-premium immediate annuity attached as a rider (the "Annuity R…
Line-of-duty disability and death benefits received specified income-tax exclusions
A state governmental retirement plan asked about special benefits for public safety officers who are permanently disabled, catastrophically injured, or killed in the line of duty. The disability statu…
Intragroup life-policy transfers preserved death-benefit exclusion
A consolidated corporate group planned to move pools of employee life insurance policies through several wholly owned subsidiaries. The first contribution would exchange the policies for cash below th…
Court-ordered restructuring of long-term care policies in an insurer rehabilitation is not a taxable event for policyholders
A state-domiciled life insurance company that sold guaranteed-renewable long-term care policies was placed into rehabilitation by a state court because its projected liabilities far exceeded its asset…
IRS preserves life-insurance exclusion in intragroup policy transfers
A corporate parent owned life-insurance policies on employees and former employees, most with built-in gain. It proposed contributing the policies through three tiers of wholly owned subsidiaries in S…
Assumption reinsurance would not restart life insurance tax tests
Members of a corporate group owned private-placement variable life insurance policies on selected employees to finance employee benefit liabilities. After an event involving the insurer, the policyhol…
Long-term care premium refund death benefit met contract rules
A life insurance company offered group long-term care coverage with a premium stabilization feature. The feature could use a calculated amount to offset future premiums or, when the insured died, pay …
Court-approved restructuring of an insolvent long-term-care insurer's policies is tax-neutral to policyholders
Two affiliated life insurance companies that sold long-term care policies became insolvent and were placed into court-supervised liquidation, and a state court approved a plan to restructure their pol…
Assumption reinsurance did not materially change an employer-owned life insurance policy
A policyholder held a group flexible-premium variable life insurance policy covering directors and highly compensated employees or individuals. The issuing insurer proposed to transfer the policy to a…
Insurer merger does not restart life policy tax tests
Two affiliated life insurance companies planned to merge, with one company surviving and assuming the other's policies. The policy terms would not change, and the surviving company would not issue rep…
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.