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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PLR 1312006: 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 1312005: 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 1312004: 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 1312003: 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 1312002: 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 1312001: 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 1311013: IRS grants extra time for a foreign entity classification election
The IRS granted a parent company 120 days to file Form 8832 for a wholly owned foreign entity to be treated as disregarded for federal tax purposes. The entity had failed to make the election on…
PLR 1311008: IRS grants extra time for a foreign entity classification election
The IRS granted a foreign entity 120 days to file Form 8832 electing to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended that classification…
PLR 1310013: Business trust receives more time to elect corporate tax classification
The IRS considered a business trust that had failed to timely file Form 8832 to elect treatment as a corporation for federal tax purposes. The IRS found that the requirements for late-election…
PLR 1308014: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1308013: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1308012: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1305006: IRS treats a contractual joint venture as a foreign business entity
A taxpayer planned to enter into a profit participation agreement with an affiliate for the operation of branches outside the United States. The agreement would give the affiliate an interest in the…
PLR 1304005: Proposed TRAC leases qualify under IRC § 7701(h)
A financial services company asked whether new leases for motor vehicles containing terminal rental adjustment clauses would qualify for the special treatment in IRC § 7701(h). The proposed…
CCA 1302026: Executor should be treated as a federal tax fiduciary
Chief Counsel Advice considers whether a person named as executor of an estate should be treated as a fiduciary for federal income tax purposes. The advice concludes that the executor should be…
PLR 1302012: IRS grants late partnership classification election relief
The IRS granted a foreign eligible entity more time to elect partnership classification for federal tax purposes. The entity had failed to timely file Form 8832 for the intended effective date. The…
PLR 1301006: IRS grants extra time for a disregarded-entity election
A business entity asked for more time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended to make the election effective on a specified…
PLR 1301005: IRS grants extra time for a disregarded-entity election
A business entity asked for more time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended to make the election effective on a specified…
PLR 1251011: IRS grants extra time to elect corporate classification
The IRS granted an eligible business entity an additional 120 days to file Form 8832 and elect to be classified as an association taxable as a corporation. The entity's default federal tax…
PLR 1250016: IRS grants extra time 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 disregarded as an entity separate from its owner for federal tax purposes. The entity was…
PLR 1249008: IRS grants more time for a partnership classification election
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had failed to timely file Form 8832, even though it was…
U.S. citizens remain subject to U.S. tax despite an Israel treaty tie-breaker
Chief Counsel advised that a dual U.S.-Israeli citizen with a permanent home in Israel may be treated as an Israeli resident for treaty purposes under the U.S.-Israel treaty tie-breaker rule. The…
PLR 1247006: IRS grants extra time for an LLC to elect corporate tax classification
The IRS granted a limited liability company 120 additional days to file an election to be treated as an association taxable as a corporation for federal tax purposes. The entity was eligible to make…
PLR 1247003: IRS grants extra time for a foreign entity to elect disregarded status
The IRS granted a foreign eligible entity 120 additional days to file an election to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification from its…
PLR 1247002: IRS grants extra time for a foreign entity to elect disregarded status
The IRS granted a foreign eligible entity 120 additional days to file an election to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification from its…
PLR 1246026: IRS grants more time for a partnership classification election
The IRS granted an entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes, effective on the date it revoked its S corporation election. The entity had…
PLR 1246016: IRS grants relief for a late disregarded-entity election
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, effective on the requested date. The entity had…
PLR 1246015: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246014: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246006: IRS grants relief for three late partnership elections
The IRS granted three foreign entities 120 days to file Form 8832 and elect partnership classification for federal tax purposes, effective on their intended dates. Each entity had failed to timely…
PLR 1246003: IRS allows an estate charitable deduction for distributed S corporation receivables
The IRS ruled that an estate could claim a charitable deduction under section 642(c) for receivables distributed to it by an S corporation and then paid to, or permanently set aside for, a…
PLR 1245003: IRS rules that a Mexican land trust arrangement is not a trust for federal tax purposes
The IRS ruled that a Mexican land trust arrangement used to hold a condominium was not a trust for U.S. federal income tax purposes. The bank holding legal title had no duty to manage, maintain, or…
PLR 1244011: IRS grants more time to elect disregarded-entity treatment
A domestic corporation formed a foreign entity and intended to elect disregarded-entity treatment for it, but did not timely file Form 8832. The IRS concluded that the requirements for late-election…
PLR 1244004: IRS approves liquidating-trust and partnership-termination treatment
A limited partnership sold its assets and wanted to distribute the proceeds and dissolve, but it faced known and possible contingent liabilities. It formed a trust to hold cash, resolve those…
PLR 1243005: IRS grants an LLC more time to elect corporate tax treatment
The IRS granted a business entity an extension of time to elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had converted from a corporation to a…
IRS permits an extended bankruptcy liquidating trust to retain its status
The IRS considered a trust created under a Chapter 11 bankruptcy reorganization plan to liquidate a debtor's estate. The trust had not completed its liquidation by the end of its current…
PLR 1240009: IRS confirms bankruptcy liquidating trust classification after extension
A bankruptcy liquidating trust asked whether it would remain a liquidating trust if the bankruptcy court extended its term by another three years. The trust had been formed under a Chapter 11 plan…
PLR 1238003: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238002: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238001: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1236024: 120-day extension granted to make an entity classification election
A foreign eligible entity asked for more time to file Form 8832 and elect partnership classification for federal tax purposes. The entity had intended the election to be effective on a specified…
PLR 1236021: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236020: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236019: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236016: 120-day extension granted for disregarded-entity election
A foreign company intended to elect disregarded-entity treatment for federal tax purposes but did not timely file Form 8832. The company asked for an extension of time to make the election effective…
IRS grants extra time to elect partnership classification
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had intended to make that classification effective…
IRS grants extra time to elect disregarded-entity treatment
The IRS granted a foreign single-member entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification to…
PLR 1233007: IRS treats an LLC's corporate election as an initial classification election
An LLC was formed under state law and remained dormant until another entity merged into it. The LLC then filed Form 8832 to elect classification as an association taxable as a corporation. The IRS…
PLR 1232031: IRS grants late-election relief for partnership classification
A domestic limited liability company intended to be treated as a partnership but did not timely file Form 8832. The taxpayer represented that it had filed federal tax returns consistently with that…
PLR 1232010: IRS grants more time to elect disregarded-entity status
A foreign limited liability company had one owner and was intended to be treated as a disregarded entity for federal tax purposes. The owner failed to timely file Form 8832, Entity Classification…
PLR 1231009: IRS grants more time to elect corporate tax classification
A business entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The IRS concluded that the entity acted…
PLR 1231008: IRS grants more time to elect partnership classification
A foreign eligible entity asked for more time to file Form 8832 and elect partnership treatment for federal tax purposes. The IRS concluded that the entity had acted reasonably and in good faith and…
PLR 1231005: IRS grants more time to elect corporate classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make the…
PLR 1230020: IRS permits a transfer between bankruptcy liquidating trusts
The IRS issued a supplemental ruling for a corporation liquidating through several trusts after a bankruptcy-related dispute over asset proceeds. A court order allowed Trust C to sell stock and…
PLR 1230014: IRS classifies a bankruptcy trust as a liquidating trust
The IRS ruled that a trust created under a Chapter 11 bankruptcy liquidation plan would be classified as a liquidating trust for federal income tax purposes. The trust was formed to liquidate and…
PLR 1230013: IRS grants more time for a foreign entity classification election
The IRS granted a group of foreign entities 120 days to file Form 8832 and elect to be treated as associations taxable as corporations for federal tax purposes. The entities intended to use that…
PLR 1230010: IRS grants more time for a foreign partnership election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the form timely for its…
PLR 1230001: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign entity 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 effective on a…
PLR 1229009: IRS grants a 120-day extension to make a partnership § 754 election
The IRS granted a partnership an additional 120 days to make a § 754 election for a specified taxable year and later years. The partnership had relied on its tax advisor to make the election but…
PLR 1229003: IRS approves stripped-certificate treatment and fixed-investment-trust classification
The IRS approved a structure in which mortgage-backed REMIC Certificates could be deposited into an Exchange Trust and exchanged for multiple classes of Exchange Certificates. The IRS ruled that the…
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.