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 1104018: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104017: IRS grants relief for a late S corporation election
A limited liability company asked the IRS to recognize a late S corporation election effective from its requested date. The company intended to file Form 2553 but did not file it on time because of…
PLR 1104016: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104015: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104014: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104009: IRS treats a potentially terminated S election as continuing
An S corporation asked for relief because certain agreements and arrangements may have terminated its S corporation election. The corporation represented that any termination was inadvertent, was…
PLR 1104008: IRS treats a potentially terminated S election as continuing
A corporation asked for relief after issuing stock warrants that may have created a second class of stock and terminated its S corporation election. The corporation was later purchased, which also…
PLR 1103034: Corporation receives relief for a late S election
A corporation intended to elect S corporation status effective on a specified date but did not timely file Form 2553. The IRS found reasonable cause for the missed election. It ruled that the…
PLR 1103030: Parent receives more time to make a QSub election for a wholly owned subsidiary
An S corporation parent asked for more time to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had contributed the subsidiary’s stock to itself but…
PLR 1103028: Company may preserve S corporation treatment after an inadvertent invalid election
A company asked for relief after discovering that its S corporation election was invalid because a trust holding company stock had not made the required qualified subchapter S trust election. The…
PLR 1103021: Company may make a late QSub election for its wholly owned subsidiary
An S corporation intended to treat its wholly owned subsidiary as a qualified subchapter S subsidiary, but it did not timely file the required election. The IRS concluded that the requirements for…
PLR 1103015: S corporation election preserved after inadvertent shareholder and ESBT election failures
A company’s S corporation election terminated when an LLC acquired its stock, and certain trusts later received the stock without timely making their required electing small business trust…
PLR 1103005: Late entity-classification and S corporation elections receive relief
A newly formed entity intended to be classified as a corporation and elect S corporation status but failed to timely file the required Forms 8832 and 2553. The taxpayer asked for an extension to…
PLR 1102049: IRS grants late S corporation election relief for reasonable cause
A corporation intended to elect S corporation status for its first tax year but did not timely file Form 2553. The IRS determined that the corporation had reasonable cause for the late election. It…
PLR 1102048: IRS grants late entity-classification and S corporation election relief
A limited liability company intended to be treated as an S corporation from a stated effective date but failed to timely file Forms 8832 and 2553. The IRS granted the company 120 extra days to elect…
PLR 1102046: IRS approves a tax-free corporate separation with S corporation elections
Two shareholders planned to separate two business lines by having an existing corporation transfer assets and liabilities to a newly formed corporation, then distribute the new corporation’s stock…
PLR 1102043: IRS allows a late S corporation election after reasonable cause was established
The taxpayer intended for its corporation to be treated as an S corporation beginning on a specified date, but it did not timely file Form 2553. The IRS concluded that the corporation had reasonable…
PLR 1102042: IRS grants relief for a late S corporation election
The corporation's shareholders intended for it to be an S corporation beginning on a specified date, but the corporation did not timely file Form 2553. The IRS concluded that the corporation…
PLR 1102034: IRS restores S corporation status after an untimely QSST election
A corporation's S corporation election terminated after stock was transferred to a trust and the beneficiary did not timely file a qualified subchapter S trust (QSST) election. The IRS concluded…
PLR 1102033: IRS preserves S corporation status after disproportionate distributions
The corporation made disproportionate distributions to its shareholders even though its governing documents provided identical distribution and liquidation rights. The IRS explained that the…
PLR 1102032: IRS grants extensions for entity classification and S corporation elections
The limited liability company intended to be treated as an association taxable as a corporation and as an S corporation, but it failed to timely file Forms 8832 and 2553. The IRS granted the company…
PLR 1102028: IRS grants extensions for association and S corporation elections
The limited liability company intended to be treated as an association taxable as a corporation and as an S corporation, but it failed to timely file Forms 8832 and 2553. The IRS granted the company…
PLR 1051017: Late S corporation election treated as timely
A corporation intended to elect S corporation status when it was incorporated but did not timely file Form 2553. The IRS determined that the corporation had reasonable cause for the late election.…
PLR 1051015: Inadvertently late S corporation election treated as timely
A corporation intended to elect S corporation status but inadvertently filed Form 2553 late. The IRS concluded that the corporation had reasonable cause for the failure. It allowed the corporation…
PLR 1051012: Late S corporation election relief granted
A corporation intended to be treated as an S corporation but did not timely file the required election. The IRS concluded that the corporation had reasonable cause for the failure and qualified for…
PLR 1051011: Late S corporation election relief granted
A corporation intended to be treated as an S corporation but did not timely file the required election. The IRS concluded that the corporation had reasonable cause for the failure and qualified for…
PLR 1051010: S corporation status preserved after possible termination
An S corporation’s shareholder engaged in an event that may have inadvertently terminated the corporation’s S election. The corporation represented that the event was not motivated by tax avoidance,…
PLR 1051009: Late S corporation election treated as timely
A corporation’s sole shareholder intended for it to be an S corporation, but Form 2553 was not timely filed. The IRS found reasonable cause for the late election and granted relief under IRC…
PLR 1051008: S corporation election cured after missing shareholder consents
A corporation attempted to elect S corporation status, but two shareholders did not provide the required consents. The IRS ruled that the election was ineffective because of the missing consents,…
PLR 1051007: Late entity-classification and S corporation elections allowed
An LLC intended to be treated as an S corporation but failed to timely file its entity-classification and S corporation election forms. The IRS granted the LLC 120 days to file Form 8832 and treat…
PLR 1050028: Late S corporation election treated as timely for reasonable cause
The IRS granted relief to a small business corporation whose shareholder intended to make an S corporation election effective on a specified date, but the election was not filed on time. The IRS…
PLR 1050025: Inadvertent S corporation termination disregarded
The IRS ruled that a corporation’s S corporation election was inadvertently terminated when two ineligible shareholders acquired stock. The shareholders later redeemed their interests, leaving the…
PLR 1050024: Late S corporation election treated as timely
The IRS granted relief to a company whose Form 2553 was not filed by the deadline for an intended S corporation election. It found that the company had reasonable cause for the late filing under IRC…
PLR 1050021: IRS restored an S corporation election after missed QSST elections
The IRS ruled that a corporation's S corporation election was inadvertently terminated when six trusts received its stock and their beneficiaries did not make the required Qualified Subchapter S…
PLR 1050019: IRS disregarded an inadvertent S corporation termination
The IRS ruled that a corporation's S corporation election was inadvertently terminated when a trust became a shareholder without filing a timely QSST election. The corporation represented that the…
PLR 1050018: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended the election to…
PLR 1050016: IRS allowed a late S corporation election effective from incorporation
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended S corporation…
PLR 1050015: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, its sole shareholder intended S corporation…
PLR 1050014: IRS allowed a late S corporation election
The IRS ruled that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation was formed under state law, intended S corporation treatment from its…
PLR 1050002: Rental income from actively managed properties is not passive investment income
An S corporation that owned and managed commercial and residential rental properties asked whether its rental income was passive investment income under IRC § 1362(d)(3). The company and its related…
CCA 1049025: Newco succeeds to an S corporation's built-in gains tax after a merger
This Chief Counsel Advice addresses a merger in which an S corporation merged into a newly formed C corporation, with the transaction treated as an asset sale for federal tax purposes. The advice…
PLR 1049023: LLC receives more time to elect corporate and S corporation status
This ruling concerns an LLC that intended to be classified as a corporation and to elect S corporation status, but did not timely file Forms 8832 and 2553. The IRS granted the LLC 120 days from the…
PLR 1049019: Corporation receives relief for a late S election
This ruling concerns a corporation whose shareholder intended S corporation treatment effective on the corporation's incorporation date, but whose S election was filed late. The IRS found reasonable…
PLR 1049017: Corporation receives relief for a late S election
This ruling concerns a corporation that intended to elect S corporation status on a specified effective date but did not timely file Form 2553. The IRS found reasonable cause for the late election…
PLR 1049011: Corporation receives relief for a late S election
This ruling concerns a corporation whose sole member intended S corporation treatment effective on a specified date, but whose election was not timely filed. The IRS found reasonable cause for the…
PLR 1049010: Corporation receives relief for a late S election
This ruling concerns a corporation that intended to elect S corporation treatment on a specified effective date but did not timely file Form 2553. The IRS found reasonable cause for the late…
PLR 1049002: Late S corporation election is accepted for reasonable cause
A corporation intended to elect S corporation status from its incorporation date but did not timely file Form 2553. The IRS concluded that the corporation established reasonable cause for the late…
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.