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 1301002: IRS allows a late S corporation election
A corporation intended to be treated as an S corporation from a specified date but did not timely file the election. The IRS found that the corporation had reasonable cause for the late filing and…
PLR 1252013: IRS grants late-election relief for S corporation status
The IRS ruled that a corporation had reasonable cause for failing to timely file its election to be treated as an S corporation. The corporation intended its S election to take effect when it was…
PLR 1252007: IRS treated an inadvertently invalid S corporation election as effective
The IRS ruled that a corporation's S corporation election was inadvertently invalid because an ineligible shareholder held an interest on the effective date. The corporation represented that the…
PLR 1252001: IRS restored S corporation treatment after an inadvertent termination
The IRS ruled that a corporation's S corporation election terminated after it issued interests to ineligible shareholders and created a second class of interests. The corporation represented that…
PLR 1251010: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation intended to be treated as an S corporation from the redacted effective date, but it did not…
PLR 1251007: IRS grants late S corporation election relief to an LLC
The IRS granted an eligible limited liability company relief for a late S corporation election. The company had elected to be treated as an association taxable as a corporation, intended to elect S…
PLR 1250018: IRS grants extra time to make a qualified subchapter S subsidiary election
The IRS granted a corporation an additional 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary, or QSub. The corporation had intended the election to take…
PLR 1250013: IRS grants relief for an inadvertent S election termination
The IRS ruled that a corporation's S election terminated when it transferred shares to a trust that was not an eligible S corporation shareholder. The corporation and its shareholders had not…
PLR 1250011: IRS grants relief for a late S corporation election
The IRS ruled that a corporation could be recognized as an S corporation from its intended effective date even though it filed Form 2553 late. The corporation's shareholders had intended S…
PLR 1249009: IRS allows a late S corporation election
The IRS allowed a corporation to make a late election to be treated as an S corporation. The corporation had intended the election to be effective on a specified date, but it did not timely file…
PLR 1249006: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation’s sole shareholder intended the election to be effective on a specified date, but the proper…
PLR 1248013: IRS allows a late S corporation election
The IRS allowed a company to be recognized as an S corporation even though it did not timely file Form 2553. The company showed reasonable cause for the late election. The IRS made the relief…
PLR 1248001: IRS restores S corporation treatment after an inadvertent termination
The IRS determined that a corporation's S corporation election had terminated after three consecutive years with accumulated earnings and profits and excessive passive investment income. The IRS…
PLR 1247012: IRS treats an invalid S corporation election as inadvertent after an IRA-owned share transfer
The IRS ruled that a corporation's S corporation election was inadvertently invalid because shares were owned by an IRA, an ineligible S corporation shareholder. After discovering the problem, the…
PLR 1247008: IRS treats an inadvertently terminated S corporation election as continuing
A corporation's S corporation election terminated when a trust shareholder failed to make a timely electing small business trust election. The IRS ruled that the termination was inadvertent and…
PLR 1247007: IRS grants late-election relief for an S corporation and its QSubs
The IRS granted a corporation 120 days to file a late S corporation election and qualified subchapter S subsidiary elections. The corporation had converted from a limited liability company and…
PLR 1246019: IRS grants relief for a late S corporation election
The IRS granted a corporation 120 days to file Form 2553 and make an S corporation election effective on its intended date. The corporation was formed under state law but did not timely file the…
PLR 1246008: IRS grants relief for possible inadvertent S corporation terminations
The IRS addressed several shareholder transactions that might have created a second class of stock and terminated a corporation's S election. It ruled that any termination caused by life insurance…
PLR 1246002: IRS restores an S election after an untimely QSST election
The IRS ruled that a corporation's S corporation election terminated when a grantor trust became ineligible as a shareholder after the deemed owner's death and the beneficiary failed to make a…
PLR 1246001: IRS grants late S corporation election relief for reasonable cause
The IRS ruled that a company had reasonable cause for failing to timely file Form 2553 to elect S corporation status. The company could file the completed form within 120 days after the ruling,…
PLR 1245014: IRS restores S corporation status after an inadvertent termination
The IRS ruled that a corporation's S corporation election was inadvertently terminated when its trust shareholders stopped qualifying as qualified subchapter S trusts. The corporation represented…
PLR 1245002: IRS treats an inadvertent S corporation termination as continuing
The IRS ruled that a corporation's S election terminated when one shareholder transferred stock to an ineligible partnership. The corporation promptly corrected the problem, and the IRS found that…
PLR 1245001: IRS treats an inadvertent S corporation termination as continuing
The IRS ruled that a corporation's S election terminated when one shareholder transferred stock to an ineligible partnership. The corporation promptly corrected the problem, and the IRS found that…
PLR 1244002: IRS grants relief for an inadvertent S-corporation termination
An S corporation transferred shares to three trusts, but the trustees did not timely make the required elections to treat the trusts as electing small business trusts. The corporation represented…
PLR 1243009: IRS preserves an S corporation election after a trust missed an ESBT election
The IRS granted relief to a corporation whose S corporation election was ineffective because a trust holding its stock did not qualify as a QSST and the trustees had not timely filed an ESBT…
PLR 1243008: IRS extends time to elect QSub treatment for three subsidiaries
The IRS granted an S corporation 120 days to file Forms 8869 and elect to treat three wholly owned subsidiaries as qualified subchapter S subsidiaries. The parent had intended to make the elections…
PLR 1243007: IRS extends time to elect QSub treatment for a subsidiary
The IRS granted an S corporation 120 days to file Form 8869 and elect to treat a wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the QSub election but…
PLR 1243002: Company gets relief for a late S corporation election
The IRS granted a company relief after it failed to timely file Form 2553 to elect S corporation status. The company had been incorporated in its state and intended the election to be effective on…
PLR 1242009: IRS grants relief for an inadvertent S corporation election failure
The IRS granted relief to a corporation whose S corporation election was ineffective because a trust that acquired its stock did not make the required qualified subchapter S trust election. The IRS…
PLR 1242006: IRS grants 120 days to make a QSub election
The IRS granted a parent corporation 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the subsidiary's stock, made an S…
PLR 1240014: IRS restores S-corporation status after missed QSST elections
A corporation asked the IRS to restore its S-corporation status after shares passed to two trusts and the trusts' beneficiaries did not make the required QSST elections. The IRS concluded that the…
PLR 1240012: IRS preserves S-corporation status after consent and stock-class issues
A corporation asked the IRS to preserve its S-corporation status after some community-property spouses failed to consent to the original S election. It also asked about composite state-tax payments…
PLR 1239001: IRS reinstates an S corporation election after an inadvertent missed ESBT election
A company treated as an S corporation transferred its stock to a trust that otherwise qualified as an electing small business trust, but the trustee did not timely file the required ESBT election.…
PLR 1238024: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238023: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238022: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238021: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238020: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238019: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238018: IRS approves a tax-free split-off and related S corporation reorganization
The IRS approved a proposed transaction in which an S corporation would transfer about half of its assets to a wholly owned QSub, distribute the QSub stock to one shareholder in exchange for that…
PLR 1238017: IRS preserves S corporation status after defective trust elections
The IRS ruled that a corporation's S election was ineffective at first because several shareholder trusts were not eligible shareholders or had made the wrong type of election. It also ruled that…
PLR 1238015: IRS preserves S corporation status after a late QSST election
The IRS ruled that an S corporation's election was inadvertently terminated when a trust failed to make a timely QSST election after the death of the original trust owner. The corporation could…
PLR 1238014: IRS preserves S corporation status after a late QSST election
The IRS ruled that an S corporation's election was inadvertently terminated when a trust failed to make a timely QSST election after the death of the original trust owner. The corporation could…
PLR 1238008: IRS restores S corporation and QSub status after an inadvertent trust-related termination
An S corporation's sole shareholder transferred the corporation's voting stock to a grantor trust and later died. The corporation's S election terminated when the trustees did not make an election…
PLR 1238007: IRS grants late-election and inadvertent-termination relief for an S corporation
The taxpayer intended for a corporation to be treated as an S corporation, but its parent was an ineligible S corporation shareholder and Form 2553 was not timely filed. The parent later distributed…
PLR 1238006: IRS grants a late S corporation election
The corporation intended to be treated as an S corporation but did not timely file Form 2553. It asked the IRS to recognize the S election from the intended effective date. The IRS found reasonable…
CCA 1237017: CCA addresses liabilities in an S corporation liquidation
Chief Counsel advice considered an S corporation that distributed assets subject to liabilities in a complete liquidation. The advice concluded that the liabilities are considered in calculating the…
PLR 1237016: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file Form 2553 to elect S corporation status. Based on the facts and representations submitted, the IRS found reasonable cause for the late…
PLR 1237015: IRS grants late QSub election relief
The IRS granted a corporation 120 days to make late elections treating four wholly owned subsidiaries as qualified subchapter S subsidiaries. The corporation had acquired the subsidiaries, failed to…
PLR 1237014: IRS grants late QSub election relief
The IRS granted a parent S corporation 120 days to make a late election treating its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the election,…
PLR 1237009: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file Form 2553 to elect S corporation status. Based on the submitted facts and representations, the IRS found reasonable cause for the late…
PLR 1237001: Administrative dissolution does not terminate an S corporation election
The IRS ruled that a corporation's administrative dissolution under state law did not terminate its S corporation status because the business continued to operate and file federal S corporation…
PLR 1236018: Late S corporation election treated as timely
A corporation's sole shareholder intended to elect S corporation status effective on a specified date, but Form 2553 was not filed on time. The corporation asked the IRS to treat the election as…
PLR 1236009: IRS grants late S corporation election relief
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The corporation established reasonable cause for the late election under IRC §…
PLR 1236004: IRS grants relief for a late S corporation election
The IRS granted a corporation relief for failing to file its S corporation election on time. It found reasonable cause under section 1362(b)(5) and allowed the election to be treated as timely made…
PLR 1236003: IRS upholds S corporation status after disproportionate distributions
The IRS ruled that a corporation's disproportionate distributions and later corrective distributions did not create a second class of stock or terminate its S corporation election. The corporation's…
Late QSST election restored S corporation and QSub status
A corporation requested relief after the income beneficiary of a trust failed to timely make the election required for qualified subchapter S trust treatment. The failure made the corporation's S…
Late S corporation election allowed for reasonable cause
A newly incorporated company intended to elect S corporation status but did not timely file Form 2553. The IRS found reasonable cause for the late filing. It allowed the company to make the election…
IRS grants late S corporation election relief
The IRS granted a corporation relief for failing to timely elect S corporation status. The corporation established reasonable cause for the late election under section 1362(b)(5). The IRS allowed…
IRS grants relief for a late S corporation election
The IRS granted a corporation 120 days to file Form 2553 and make a late election to be treated as an S corporation. The corporation had intended the election to take effect on a specified date, but…
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.