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 1228032: IRS grants 120-day extension to elect disregarded-entity status
A domestic corporation asked for more time to elect to treat a foreign subsidiary as disregarded for federal tax purposes. The corporation said it had intended the election to be effective on an…
PLR 1228031: IRS grants 120-day extension to elect disregarded-entity status
A domestic corporation asked for more time to elect to treat a foreign subsidiary as disregarded for federal tax purposes. The corporation said it had intended the election to be effective on an…
PLR 1226019: IRS approves a voting trust as an S corporation shareholder
The IRS rules that a proposed voting trust will be classified as an investment trust for federal income tax purposes. It also rules that the trust will be a qualified voting trust and a permitted S…
PLR 1226012: IRS grants six foreign companies more time to file entity classification elections
Six foreign companies intended to be treated as corporations from their formation dates but inadvertently failed to file Form 8832. The IRS concluded that the requirements for relief under the…
PLR 1224022: IRS grants foreign entities more time to elect disregarded status
The IRS granted three foreign limited liability companies 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities missed the filing deadline…
PLR 1224021: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224020: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224009: IRS grants more time for a foreign disregarded-entity election
The IRS granted foreign subsidiary Y 120 days to file Form 8832 and elect to be treated as a disregarded entity effective on its formation date. Y had missed the filing deadline, while its parent,…
PLR 1224008: IRS grants more time for a foreign partnership election
The IRS granted foreign company X 120 days to file Form 8832 and elect to be treated as a partnership effective on a specified earlier date. X had been classified by default as an association and…
PLR 1223010: IRS grants ten foreign entities more time to elect disregarded status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1223009: IRS grants ten foreign entities more time to elect partnership status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as partnerships for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1222026: IRS grants more time to elect disregarded-entity 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 intended that classification from its…
CCA 1221015: Chief Counsel says a disregarded entity is not a partnership partner
Chief Counsel Advice addressed whether a partnership existed for federal tax purposes. The advice concluded that a redacted entity was disregarded as separate from its owner and therefore was not…
PLR 1221005: IRS grants more time to elect corporate tax classification
The IRS granted a limited liability company 120 additional days to file Form 8832 and elect to be treated as a corporation for federal tax purposes. The company had intended to be classified as a…
PLR 1219007: Extension granted to elect disregarded-entity status
An entity asked for more time to file an election to be treated as a disregarded entity for federal tax purposes. The IRS concluded that the entity met the requirements for relief under the…
PLR 1216024: IRS grants more time for a partnership classification election
A foreign business entity intended to elect partnership classification for federal tax purposes but failed to timely file Form 8832. The IRS concluded that the requirements for relief under Treas.…
PLR 1216021: IRS grants a foreign entity more time to elect partnership classification
A foreign entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under the regulations were…
PLR 1216014: IRS grants more time for a foreign entity to elect partnership status
A foreign limited liability partnership intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The entity had sold an interest in a domestic limited…
PLR 1216012: IRS grants more time for a foreign entity to elect partnership status
A foreign entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under Treas. Reg. § 301.9100-3…
PLR 1216004: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216003: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216002: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216001: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
IRS approves an LLC's change to disregarded-entity status
The IRS consented to an LLC's request to change its federal tax classification from an association taxable as a corporation to a disregarded entity. The LLC had previously changed its classification…
IRS consents to an LLC's second classification change
The IRS consented to an LLC's request to change its federal tax classification from an association taxable as a corporation to a disregarded entity. The LLC had previously changed its classification…
PLR 1213015: IRS grants late relief for a foreign entity's partnership election
The IRS granted a foreign eligible entity 120 days to file Form 8832 electing partnership treatment for federal tax purposes. The entity intended to make that election effective on a specified date,…
PLR 1213007: Foreign entity gets extra time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity 120 days to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The entity was formed in a foreign country and was…
PLR 1208036: IRS approves tax treatment for four bankruptcy liquidation trusts
A corporation in Chapter 11 bankruptcy proposed a liquidation plan that would create four trusts to resolve different groups of claims and distribute remaining assets. The IRS ruled that the…
PLR 1208020: IRS grants late disregarded-entity classification election
The IRS granted a foreign single-owner entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended the classification to apply…
PLR 1208010: IRS approves a late change to entity classification
The IRS consented to a foreign eligible entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity represented that a change in…
PLR 1208009: IRS approves a late change to entity classification
The IRS consented to a foreign eligible entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity represented that a change in…
PLR 1206013: Extension granted to file an entity classification election
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended to make the election effective…
PLR 1206012: Extension granted to elect association treatment for federal tax purposes
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect to be treated as an association taxable as a corporation. The entity was eligible to make the election but…
PLR 1206008: Extension granted for a late disregarded-entity election
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded from its owner for federal tax purposes. The entity was eligible to make the election…
PLR 1206007: Extension granted for a late disregarded-entity election
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded from its owner for federal tax purposes. The entity was eligible to make the election…
CCA 1205007: Credit card interest follows the customer’s residence, while overseas ATM processing fees are U.S.-source income
The Office of Chief Counsel analyzed the source of credit card interest, certain fees treated as original issue discount, and fees for processing withdrawals on foreign ATMs. It concluded that…
PLR 1202013: IRS grants late entity classification elections
The IRS granted three foreign entities 120 more days to file late entity classification elections. Two entities were allowed to elect partnership status, and a third was allowed to elect…
PLR 1202011: IRS permits an early entity classification change
The IRS permitted a foreign entity to elect classification as an association taxable as a corporation within 60 months of a prior entity classification election. The entity had previously elected…
PLR 1201008: IRS grants more time for a partnership basis election
The IRS granted a lower-tier partnership 120 days to make a late IRC § 754 election. An upper-tier partnership had acquired an interest in the lower-tier partnership, and the lower-tier partnership…
PLR 1151010: IRS grants time to elect disregarded-entity treatment
The IRS granted a foreign business entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was wholly owned by a husband and wife as…
PLR 1150017: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150016: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150015: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150014: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150013: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150012: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150011: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150010: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150009: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150008: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150007: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150006: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150005: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150004: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150003: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150002: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150001: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
IRS granted late foreign-entity classification elections
The IRS granted eight foreign entities 120 days to file late Form 8832 entity-classification elections. The entities had failed to file the forms due to inadvertence. The IRS found that the…
PLR 1147002: IRS grants late election for disregarded-entity treatment
A foreign corporation with one owner asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The corporation had failed to file the form by…
PLR 1146004: IRS grants more time for a foreign LLC to elect its tax classification
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect a federal tax classification different from its default classification. The company had inadvertently missed…
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.