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 1031025: IRS granted an extension to elect corporate treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a corporation for U.S. income tax purposes. The entity had a single owner without limited liability…
PLR 1031024: IRS granted an extension to elect disregarded-entity treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for U.S. income tax purposes. The entity had inadvertently failed to timely…
PLR 1031023: IRS granted an extension to elect partnership treatment
The IRS granted an entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was organized under foreign law by two owners with…
PLR 1031022: IRS granted an extension to elect disregarded-entity treatment
The IRS granted an entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was organized under foreign law by a single…
PLR 1031014: IRS granted an extension to elect disregarded-entity treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was formed under foreign law and intended…
PLR 1031004: IRS granted an extension to elect corporate treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity was formed under…
PLR 1029008: The IRS granted a foreign entity more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had inadvertently failed to file 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.