Ezel / IRS Rulings / 200934044

CCA 200934044: Isle of Man companies and per se corporation status

Number
200934044
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Associations v. Corporations; Kintner-Type
Topics
Entity classification
Code sections
§ 7701
Ruling dated
April 29, 2009
Publicly released
August 21, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice clarifies that no Isle of Man companies are per se corporations under the referenced regulation. The advice addresses the classification of those companies under the entity-classification rules in the context identified by UILC 7701.01-00.

Ruling snapshot

  • Question: Are any Isle of Man companies per se corporations under the referenced regulation?
  • Outcome: Advice given
  • Key authorities: IRC § 7701

Full text (IRS public release)

ID: CCA-429131-09 Number: 200934044
Release Date: 8/21/2009
Office: ----------
UILC: 7701-01.00

From: ----------------
Sent: Wednesday 4/29/09 1:21 PM
To: ---------------
Cc:
Subject:

I meant to say there are no Isle of man companies that are per se corporations under
the -2 regulation.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace