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 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…
IRS grants extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity's classification election
The IRS granted a foreign entity an additional 120 days to file Form 8832 and make an election to be treated as a partnership for federal tax purposes. The facts section says the entity intended…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect disregarded entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election by the…
IRS grants extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by the stated…
PLR 1331001: IRS grants relief for a foreign entity classification election
The IRS consented to a foreign entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity had previously changed its…
PLR 1330029 grants late election relief for foreign entity classification
The IRS grants a foreign eligible entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had inadvertently failed to timely file Form 8832.…
PLR 1330028 grants late disregarded-entity election relief
The IRS grants a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file Form 8832. The IRS concludes that…
PLR 1330014 grants more time to elect partnership classification
The IRS grants an entity 120 additional days to file an election to be treated as a partnership for federal tax purposes. The entity had intended to change its classification from an association…
PLR 1330013 grants more time to elect corporate classification
The IRS grants a foreign entity 120 additional days to file Form 8832 electing to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make that…
PLR 1330009 grants more time to elect disregarded-entity status
The IRS grants a foreign subsidiary 120 additional days to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The subsidiary had always intended to make that…
PLR 1330008 approves a mortgage-loan sale by a governmental bond agency
The IRS rules that a state governmental housing agency's proposed sale of mortgage loans purchased with tax-exempt bond proceeds will not cause the agency or any portion of it to be treated as a…
PLR 1328003: IRS approves a cross-border liquidation and reorganization
The IRS approved specified tax treatment for a proposed cross-border corporate restructuring involving a foreign parent, a target corporation, and multiple subsidiaries. The rulings cover…
CCA 1323015: Collaboration is a partnership and cannot elect out of subchapter K
The IRS analyzed a collaboration between two corporations that developed and commercialized a product. It concluded that the collaboration was a partnership for federal tax purposes because the…
PLR 1322038: IRS grants a foreign entity 120 more days to elect disregarded-entity status
The IRS granted a foreign business entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election…
PLR 1322037: IRS grants a foreign entity 120 more days to elect disregarded-entity status
The IRS granted a foreign business entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election…
PLR 1322022: IRS grants more time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification…
PLR 1322021: IRS grants more time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was eligible for that classification but had…
PLR 1321015: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321014: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321013: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321004: IRS grants late-election relief for foreign entity classification
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election…
PLR 1321001: IRS grants two foreign entities more time to elect disregarded-entity status
Two foreign entities asked the IRS for more time to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. Their parent intended the elections to be effective on…
PLR 1320016: IRS grants more time to elect corporate tax classification
The IRS considered a business entity's request for extra time to elect to be treated as an association taxable as a corporation. The entity had been formed in a state, defaulted to partnership…
PLR 1314039: Extension granted to correct a foreign entity classification election
A foreign single-owner entity intended to elect disregarded-entity status for federal tax purposes, but it mistakenly filed Form 8832 to be treated as an association taxable as a corporation. The…
PLR 1314015: IRS grants an LLC more time to elect partnership classification
A limited liability company asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The LLC was eligible for partnership treatment but missed the…
PLR 1314010: IRS grants a foreign entity more time to elect disregarded-entity status
A foreign entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. It was eligible for that classification but inadvertently missed the…
PLR 1313011: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association, treated as a corporation, for federal tax purposes. The company had missed the…
PLR 1313010: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association, treated as a corporation, for federal tax purposes. The company had missed the…
PLR 1313009: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
PLR 1313008: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
PLR 1313007: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
PLR 1313006: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
PLR 1313005: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
PLR 1313004: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association for federal tax purposes. The company had missed the deadline for making the…
CCA 1312033: a foreign entity's classification affected whether TEFRA applied
Chief Counsel advised that filing Form 1120F did not by itself establish that a foreign partner was treated as a C corporation for TEFRA purposes. Under the check-the-box regulations, an eligible…
PLR 1312015: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312014: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312013: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312012: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312011: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312010: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312009: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312008: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312007: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
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.