IRS Written Determinations

IRS Denies Tax-Exempt Status Under IRC 501(c)(3)

The IRS has issued a final determination denying tax-exempt status to an organization under IRC Section 501(c)(3). The organization failed to file a protest within 30 days of a proposed adverse determination. As a result, donors cannot deduct contributions, and the organization must file federal income tax forms.

IRS Determination on FPA Issuance and NAP Mailing Rules

The IRS has issued a determination regarding the issuance of FPA (presumably related to tax forms or filings) and rules for NAP (likely a mailing process). This guidance clarifies specific procedural requirements for taxpayers and the agency.

IRS Written Determination 202611008 - Qualified Opportunity Fund Certification Extension

The IRS has released Written Determination 202611008, granting a taxpayer an extension of time to self-certify as a Qualified Opportunity Fund (QOF) by filing Form 8996. This determination provides guidance on relief for late elections under sections 301.9100-1 and 301.9100-3.

IRS Written Determination: Extension of Time for Entity Classification Election

The IRS released Written Determination 202611007, granting a foreign company an extension of time to file an election to be classified as a disregarded entity for federal tax purposes. This determination provides relief under § 301.9100-3 for a late filing of Form 8832.

IRS Private Letter Ruling on Portability Election Extension

The IRS has issued Private Letter Ruling 202611006, granting an extension of time for a decedent's estate to make a portability election. This ruling allows the surviving spouse to utilize the deceased spouse's unused exclusion amount.

IRS denies tax exemption for IRC Section 501(c)(6) organization

IRS denies tax exemption for IRC Section 501(c)(6) organization

IRS Grants Ruling on Substitute Mortality Tables for Pension Plans

The IRS has granted a ruling allowing a taxpayer to use substitute mortality tables for pension plan computations under section 430 of the Internal Revenue Code. This approval is effective for up to 3 plan years beginning with the 2026 plan year.