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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
Foreign entity receives late partnership-classification election relief
A foreign eligible entity intended to be treated as a partnership for U.S. federal tax purposes from its formation date but failed to timely file Form 8832. The IRS concluded that the entity…
Retiree VEBA settlement is exempt function income
A tax-exempt voluntary employees' beneficiary association was created through a bankruptcy settlement to provide medical reimbursements for eligible retirees and their families. The debtors paid the…
LLC receives late partnership classification election relief
A limited liability company had elected S corporation treatment when it was formed but later intended to change its federal classification to a partnership. It failed to file Form 8832 by the…
Late disregarded-entity election receives 120-day extension
A foreign eligible entity with one owner intended to be treated as disregarded for federal tax purposes but did not timely file Form 8832. The IRS concluded that the entity satisfied the…
Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but failed to file Form 8832 on time. The IRS found that the entity satisfied the requirements for…
Foreign entity received more time to elect disregarded status
A corporate group formed a wholly owned foreign eligible entity and intended from formation to treat it as disregarded for federal tax purposes. The entity did not timely file Form 8832 to make that…
Nonprofit home-financing LLC was excluded from taxable mortgage pool treatment
Two section 501(c)(3) organizations used a nonprofit limited liability company to finance home loans for low- and moderate-income borrowers in communities needing stabilization. The LLC proposed…
Joint nonprofit housing program's financing LLC avoided taxable mortgage pool status
Two section 501(c)(3) organizations formed a nonprofit limited liability company to issue multiple-maturity notes secured by home loans to low- and moderate-income borrowers. The loans supported…
Nineteen foreign subsidiaries received more time to elect disregarded status
A taxpayer requested late entity-classification elections for 19 foreign subsidiaries. Each subsidiary was eligible to elect its federal tax classification but had failed to timely file Form 8832…
Foreign entity received more time to elect disregarded status
A foreign entity with one shareholder intended to elect disregarded-entity treatment but inadvertently failed to file Form 8832 on time. Based on the submitted information and representations, the…
Foreign subsidiary receives extension for disregarded-entity election
A company owned a foreign subsidiary that was eligible to elect disregarded-entity status for federal tax purposes. The owner intended that classification to take effect when the subsidiary was…
Foreign entity receives extension for disregarded-entity election
A foreign entity was eligible to elect disregarded-entity status for federal tax purposes but did not timely file Form 8832. The entity requested discretionary relief to make the election effective…
Foreign entity receives extension for partnership election
A foreign entity was eligible to elect partnership status for federal tax purposes but did not timely file Form 8832. The entity requested discretionary relief to make the election effective on its…
Foreign subsidiary receives late disregarded-entity election relief
A parent company intended its wholly owned foreign subsidiary to be treated as a disregarded entity from the subsidiary's formation date. The subsidiary was eligible for that classification but did…
Trust may distribute series LLC interests as securities partnerships
The IRS approved a trust's plan to place diversified equity and fixed-income portfolios into two series of an LLC and distribute the series interests to remainder beneficiaries. Each series would…
Entity receives 120 days to correct corporate classification date
A single-owner eligible entity intended to elect corporate tax classification effective on one redacted date. Its Form 8832 inadvertently specified a different effective date. The IRS found that the…
Bankruptcy trust qualifies as a liquidating grantor trust
Chapter 11 debtors planned to transfer most of their cash and remaining assets to a trust for liquidation and distribution to unsecured creditors. The trust would not continue a trade or business…
Foreign entity receives 120 days for late partnership election
A foreign eligible entity failed to timely file Form 8832 electing partnership classification for federal tax purposes. It asked for regulatory relief so the election could take effect on the…
Foreign business receives late partnership classification relief
A foreign eligible entity missed the deadline for filing Form 8832 to elect partnership treatment for federal tax purposes. It requested an extension so the classification could apply from its…
Foreign entity received 120 days to make a disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment from a specified effective date but did not timely file Form 8832. The entity represented that it was eligible to make that…
LLC receives 120 days to make a late corporate election
A limited liability company intended from its formation date to be classified as an association taxable as a corporation for federal tax purposes. It inadvertently failed to file Form 8832 by the…
Extended bankruptcy trust remains a liquidating trust
A trust created under a Chapter 11 plan was established to liquidate and distribute estate assets, not to carry on a business. Its agreement limited retained cash and investments, required periodic…
IRS grants more time for a foreign entity to elect disregarded status
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file the form for its…
IRS grants more time for a disregarded-entity election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity status for federal tax purposes. The entity intended the election to be effective on a…
IRS grants more time to elect partnership classification for a foreign entity
The IRS granted a foreign eligible entity 120 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had intended that classification from its…
IRS grants more time for a foreign entity to elect partnership status
The IRS granted a foreign eligible entity 120 more days to file Form 8832 and elect partnership classification for federal tax purposes effective on the requested date. The entity had several owners…
IRS grants more time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity 120 more days to file Form 8832 and elect disregarded-entity classification for federal tax purposes effective on the requested date. The entity had one…
IRS approves tax treatment for TRAC leases in a vehicle refinancing
A vehicle leasing business used terminal rental adjustment clauses, or TRACs, in leases of motor vehicles. It planned to transfer beneficial ownership of leased vehicles to a special-purpose entity…
Foreign entities granted extra time to elect corporation status
The IRS granted seven foreign entities an extension of time to file Form 8832 entity-classification elections. The entities had failed to timely file valid elections to be classified as corporations…
LLC granted extra time to elect corporation classification
The IRS granted a domestic LLC 120 additional days to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC's members had intended the election to be…
PLR 1352004: late entity classification election
The ruling concerns a foreign eligible entity that failed to timely elect partnership classification for federal tax purposes. The entity later became wholly owned by a corporation, which caused it…
PLR 1349001: Grantor trust treatment controls a proposed asset transfer
The IRS considered two trusts, one revocable and one irrevocable, and a proposed transfer of a partnership interest from the first trust to an LLC for cash and a promissory note. The IRS ruled that…
PLR 1348004: IRS grants a foreign entity more time to elect disregarded-entity status
A foreign entity wholly owned by one person was eligible to elect to be treated as a disregarded entity for federal tax purposes, but it did not file Form 8832 by the applicable deadline. The IRS…
PLR 1348003: IRS grants a foreign entity more time to elect partnership status
A foreign entity owned by two persons was eligible to elect partnership classification for federal tax purposes, but it did not file the required entity classification election on time. The IRS…
PLR 1348002: IRS grants a foreign entity more time to elect disregarded-entity status
A foreign entity wholly owned by one person was eligible to elect to be treated as a disregarded entity for federal tax purposes, but it did not file the entity classification election on time. The…
PLR 1347008: IRS grants 120 days to make a late foreign-entity partnership election
A foreign eligible entity missed the deadline to file Form 8832 electing partnership classification for federal tax purposes. The entity asked for relief under the regulations that permit an…
PLR 1347007: IRS grants 120 days for two foreign entities to make a late corporation election
Two foreign entities intended to be treated as corporations for federal tax purposes but failed to timely file Form 8832. They asked the IRS for an extension under the regulations governing late…
PLR 1345022: IRS grants extra time to elect partnership classification
A foreign private limited company asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The company was eligible to make the election but did not…
PLR 1345016: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345015: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345014: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345013: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345012: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345011: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345010: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345009: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345008: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345007: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345002: Entity receives more time to elect partnership classification
An eligible foreign entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under the…
PLR 1342002: IRS grants more time to elect disregarded-entity status
A foreign entity eligible to choose its federal tax classification intended to be treated as a disregarded entity. It failed to timely file Form 8832 because of inadvertence. The IRS found that the…
PLR 1341025: IRS grants late entity-classification election relief
The IRS granted an entity 120 days to make a late election to be treated as an association taxable as a corporation for federal tax purposes. The entity was eligible to elect its classification but…
PLR 1341001: IRS preserves liquidating trust status after a court-ordered extension
The IRS ruled that a trust created in a Chapter 11 bankruptcy liquidation remained a liquidating trust for federal tax purposes after the bankruptcy court extended its term. The remaining assets…
PLR 1338041: IRS grants late election relief for foreign entity classification
A foreign eligible entity was treated by default as an association taxable as a corporation, but it intended to be classified as a disregarded entity for federal tax purposes. The entity failed to…
PLR 1338037: IRS grants more time for a foreign entity to elect disregarded-entity status
A foreign corporation that was eligible to choose its federal tax classification failed to timely file Form 8832 to be treated as a disregarded entity effective on Date 1. The entity asked for…
PLR 1338032: IRS grants five foreign companies more time to elect corporate treatment
Five foreign companies were eligible to elect to be treated as associations taxable as corporations for federal tax purposes but failed to timely file Form 8832. They asked for relief under Treas.…
PLR 1338030: IRS grants more time for a foreign entity to elect corporate treatment
A foreign eligible entity intended to be treated as an association taxable as a corporation but failed to timely file Form 8832. The entity requested relief under Treas. Reg. § 301.9100-3 and…
PLR 1337012: Vehicle-leasing trusts receive qualified lease and disregarded-entity treatment
A vehicle-leasing corporation asked about a financing structure using a First Tier Trust, a Titling Trust, sub-trusts, a special purpose vehicle, and a securitization trust. The IRS ruled that the…
PLR 1336005: IRS grants more time for an entity classification election
An entity formed in a state wanted to elect to be treated as an association taxable as a corporation for federal tax purposes. It was eligible to make the election under the entity-classification…
PLR 1336001: IRS consents to a change from corporation to partnership classification
The taxpayer was a limited liability company that had elected S corporation status. A foreign entity later acquired an ownership interest, terminating the S corporation election, and new owners…
IRS grants more time for a disregarded-entity classification election
The IRS granted a foreign eligible entity 120 days to make a late election to be treated as a disregarded entity for federal tax purposes. The entity had not timely filed Form 8832, 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.