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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Foreign entity may file a late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity status but failed to file Form 8832 on time. The IRS found that it met the standards for discretionary relief and granted 120 days to…
Foreign entity receives 120 days for late partnership election
A foreign eligible entity intended to be classified as a partnership for federal tax purposes from a specified date, but inadvertently failed to file Form 8832 on time. The IRS found that the entity…
Foreign entity gets more time for disregarded-entity election
A wholly owned foreign eligible entity intended to elect disregarded-entity status effective on a redacted date, but inadvertently failed to file Form 8832 on time. It requested relief under the…
Entity gets more time to elect partnership status
A domestic eligible entity with multiple members intended to be treated as a partnership for federal tax purposes but did not file Form 8832. It asked for an extension under the regulatory…
Foreign subsidiary gets late disregarded-entity election relief
A domestic corporation's wholly owned foreign subsidiary intended to elect disregarded-entity status from a specified date but failed to file a valid Form 8832 on time. The foreign subsidiary…
Foreign subsidiary gets late disregarded-entity election relief
A domestic corporation's wholly owned foreign subsidiary intended to elect disregarded-entity status from a specified date but failed to file a valid Form 8832 on time. The foreign subsidiary…
Foreign subsidiary gets late disregarded-entity election relief
A domestic corporation's wholly owned foreign subsidiary intended to elect disregarded-entity status from a specified date but failed to file a valid Form 8832 on time. The subsidiary sought relief…
Foreign subsidiary gets late disregarded-entity election relief
A domestic corporation's wholly owned foreign subsidiary intended to elect disregarded-entity status from a specified date but failed to timely file a valid Form 8832. It requested an extension…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to elect treatment as an entity disregarded from its single owner for federal tax purposes but did not timely file Form 8832. It represented that the failure was…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded from its single owner for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity planned to be treated as disregarded from its single owner for federal tax purposes but inadvertently missed the Form 8832 filing deadline. It represented that it acted…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to elect federal tax treatment as an entity disregarded from its single owner but failed to timely file Form 8832. It represented that the mistake was inadvertent,…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to elect treatment as disregarded from its single owner for federal tax purposes but inadvertently did not file Form 8832 by the deadline. It represented that it…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity meant to elect federal tax treatment as disregarded from its single owner but inadvertently missed the deadline for Form 8832. It represented that it acted reasonably and…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded from its single owner for federal tax purposes but inadvertently failed to timely file Form 8832. It represented that it acted in good…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently filed no timely Form 8832. It represented that it acted reasonably and in good faith…
Foreign entity receives more time to elect partnership status
A foreign eligible entity with multiple owners intended to change its federal tax classification to a partnership but did not timely file Form 8832. It represented that it had no valuable assets or…
Foreign entity receives more time to elect corporate status
A foreign eligible entity intended to elect classification as an association taxable as a corporation from its formation date but inadvertently failed to timely file Form 8832. It represented that…
Late entity classification election relief granted
A foreign entity intended to be treated as disregarded from its owner for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the requirements for…
Late disregarded-entity election relief approved
A foreign entity intended to be treated as disregarded from its owner for federal tax purposes but inadvertently failed to file Form 8832 by the deadline. The IRS concluded that the entity met the…
Foreign entity gets 120 days for late disregarded election
A foreign entity with one owner intended to elect disregarded-entity status but inadvertently failed to file Form 8832 on time. It represented that it was eligible to make the election, had acted…
Foreign entity receives late disregarded-election relief
A foreign entity wholly owned by an individual resident in a U.S. state failed to file Form 8832 on time to elect disregarded-entity status. The IRS found that the entity satisfied the standards for…
Foreign entity receives more time for disregarded entity election
A foreign eligible entity with one owner failed to file Form 8832 on time to elect disregarded entity status. The IRS found that the entity met the standards for discretionary relief under Treas.…
Retroactive REIT election fails the section 351 control test
A failed financial institution formed a single-member LLC, transferred securities to it, and later sold the LLC as part of an asset acquisition. The LLC subsequently made a retroactive election to…
Late disregarded-entity election allowed from a later date
A foreign eligible entity with one owner was treated by default as an association taxable as a corporation. It inadvertently failed to file Form 8832 on time and asked to elect disregarded-entity…
Foreign entity receives 120 days for late partnership election
A foreign eligible entity failed to file Form 8832 on time to elect partnership classification from a redacted effective date. The IRS concluded that the entity met the standards for discretionary…
Late disregarded-entity election relief granted
A foreign single-owner entity intended to elect disregarded-entity status but did not file Form 8832 on time. It asked for an extension under the regulatory-election relief rules. Based on the…
Foreign entity receives late classification election relief
A foreign entity wanted a federal tax classification different from its default classification but inadvertently missed the Form 8832 deadline. The IRS concluded that the entity met the standards…
Late Form 8832 relief granted from formation date
A foreign entity wanted to elect a federal tax classification other than its default but inadvertently failed to timely file Form 8832. The IRS concluded that the entity satisfied the standards for…
Formation-date classification election allowed late
A foreign entity intended to choose a tax classification other than its default classification but inadvertently failed to file Form 8832 on time. The IRS found that the entity met the good-faith…
Foreign entity may backdate late Form 8832 to formation
A foreign entity sought a tax classification different from its default but missed the deadline for Form 8832. The IRS concluded that it acted reasonably and in good faith and that granting relief…
Late entity classification election approved
A foreign entity inadvertently failed to timely file Form 8832 to choose a classification different from its default federal tax status. The IRS determined that the entity qualified for…
IRS permits late classification election from formation
A foreign entity intended to elect out of its default federal tax classification but inadvertently missed the Form 8832 filing deadline. The IRS concluded that the entity met the standards for late…
Late Form 8832 election may use formation date
A foreign entity wanted a classification other than its default federal tax classification but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied the…
Foreign entity receives 120 days to make a late partnership election
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. It requested discretionary relief under the regulatory-election…
Another foreign entity receives 120 days for a late partnership election
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but failed to timely file Form 8832. It requested discretionary relief under the regulatory-election…
Foreign entity gets 120 days to make its partnership election
A foreign eligible entity intended to elect partnership classification for federal tax purposes but failed to timely file Form 8832. It requested discretionary relief under the regulatory-election…
Foreign entity obtains 120 days for a late partnership election
A foreign eligible entity wanted partnership classification for federal tax purposes but failed to timely file Form 8832. It requested relief under the discretionary extension rules for regulatory…
Foreign entity receives 120 days for a late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its single owner for federal tax purposes but failed to timely file Form 8832. It requested discretionary extension relief under…
Foreign entity receives late Form 8832 election relief
A foreign eligible entity wanted a federal tax classification different from its default classification but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied…
Foreign entity gets late partnership-classification election
A foreign eligible entity and its two members intended partnership classification from the entity's formation date but inadvertently failed to file Form 8832. The IRS found that the entity met the…
Post-reorganization entity gets late disregarded election
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Reorganized foreign subsidiary gets Form 8832 extension
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Late disregarded election after reorganization is approved
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Foreign subsidiary receives post-reorganization election relief
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Reorganized subsidiary gets retroactive disregarded status
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Late Form 8832 relief follows foreign reorganization
After a corporate reorganization, a foreign eligible entity became wholly owned by another foreign entity whose owners included a member of a U.S. consolidated group. The subsidiary failed to timely…
Reorganized foreign entity gets late partnership election
After a corporate reorganization, a foreign eligible entity became equally owned by another foreign entity and an unrelated foreign third party. It failed to timely file Form 8832 for intended…
Foreign partnership classification election gets extension
After a corporate reorganization, a foreign eligible entity became equally owned by another foreign entity and an unrelated foreign third party. It failed to timely file Form 8832 for intended…
Foreign entity gets late disregarded classification election relief
A foreign entity with one owner was eligible to elect disregarded-entity status but did not timely file Form 8832 for its intended effective date. The owner had consistently filed personal U.S. tax…
Foreign entity gets late disregarded entity election relief
A foreign eligible entity missed the deadline to file Form 8832 electing disregarded-entity treatment from its formation date. The IRS concluded from the submitted information and representations…
Foreign entity gets late partnership classification election
A foreign eligible entity acquired a second owner but did not timely file Form 8832 to elect partnership classification from that date. A related entity later bought the remaining interest and…
Foreign entity gets late disregarded classification election
A foreign eligible entity failed to timely file Form 8832 to elect disregarded classification from its formation date. The IRS concluded that the entity satisfied the standards for discretionary…
Pre-1987 foreign taxes cannot enter post-1986 credit pools
A U.S. parent claimed deemed-paid foreign tax credits after check-the-box elections produced deemed liquidations of several controlled foreign corporations. Part of the claimed credit came from…
Failed-bank asset transfer blocks carryover basis through late REIT election
A bank acquired assets and deposit liabilities from a failed institution in a transaction supported by federal net worth assistance and loss guarantees. The acquiring group later filed a REIT return…
Late disregarded entity election receives 120-day extension
A state-law entity had elected S corporation treatment from its formation date. When its S election later terminated, it intended to change its federal classification to a disregarded entity…
Subsidiaries may correct disregarded entity election date
An S corporation acquired two single-member limited liability companies whose prior owners had elected S corporation treatment. After the reorganization, the parent intended both subsidiaries to…
LLC receives late corporate classification election relief
A limited liability company intended to be classified as an association taxable as a corporation for federal tax purposes. It failed to timely file Form 8832, so its desired classification did not…
LLC may elect partnership status after ownership change
A limited liability company began as a disregarded entity and later elected S corporation status, which caused it to be classified as an association taxable as a corporation. New owners then…
LLC receives 120 days for late corporate-classification election
A domestic single-member LLC intended from its formation date to be treated as an association taxable as a corporation but failed to timely file Form 8832. The IRS concluded that the entity…
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.