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 1052001: Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 120 days to file an election to be treated as a partnership for federal tax purposes. The entity had intended to make the election effective…
PLR 1051013: Late disregarded-entity election granted extra time
A foreign entity with one owner intended to be treated as a disregarded entity for U.S. federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief under…
PLR 1050011: IRS classified a foreign pension organization as a trust for federal tax purposes
The IRS considered the federal tax classification of a foreign organization created to provide disability, old age, and death benefits to covered employees and their beneficiaries. The organization…
PLR 1050001: IRS grants late-election relief for a foreign entity to be treated as disregarded
The taxpayer was a foreign business entity with one owner and limited liability. It intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS…
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.