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 1032030: The IRS preserved an S corporation election after trusts failed to make ESBT elections
The IRS ruled that a corporation's S corporation election was ineffective because three shareholder trusts had not made the required elections to qualify as electing small business trusts. The…
PLR 1032029: The IRS granted relief for a late S corporation election
The IRS ruled that a corporation's late S corporation election could be treated as timely made because the corporation established reasonable cause for missing the filing deadline. The relief…
PLR 1032028: The IRS granted late-election relief for an LLC seeking S corporation status
The IRS ruled that a limited liability company could be recognized as an S corporation effective on the requested date. The LLC had timely elected to be classified as an association taxable as a…
PLR 1032027: The IRS granted relief for a late S corporation election
The IRS ruled that a corporation's late S corporation election could be treated as timely made because the corporation established reasonable cause for missing the filing deadline. The relief…
PLR 1032020: S corporation election reinstated after inadvertent trust election failures
An S corporation's stock was transferred to a trust that was intended to qualify as a QSST, but the beneficiary did not make a timely QSST election. After the beneficiary's death, the stock was…
PLR 1032018: S corporation status preserved after missed ESBT election
An S corporation's stock passed from a shareholder's estate to a testamentary trust. The trust qualified as a shareholder for two years, but its trustee failed to properly file the election to treat…
PLR 1031030: IRS treated an S corporation as continuing after an inadvertent termination
The IRS concluded that an S corporation's election had terminated because the corporation had accumulated earnings and profits and more than 25 percent of its gross receipts were passive investment…
PLR 1031010: IRS allowed a late S corporation election
The IRS ruled that a corporation could 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 its Form 2553 was not…
PLR 1031003: IRS granted more time to make QSub elections
The IRS granted a corporation an extension of time to file Forms 8869 for 24 subsidiaries and elect to treat them as qualified subchapter S subsidiaries. The corporation intended the elections to be…
PLR 1031002: IRS granted more time to make QSub elections
The IRS granted a corporation an extension of time to file Forms 8869 for seven subsidiaries and elect to treat them as qualified subchapter S subsidiaries. The corporation intended the elections to…
CCA 1030024: CFC inclusions were not passive investment income for S corporation tests
Chief Counsel Advice addressed how a domestic S corporation should classify income and dividends involving its controlled foreign corporations and related domestic subsidiaries for the passive…
PLR 1030022: Late S corporation election relief granted
The IRS granted a corporation relief for its late election to be treated as an S corporation. The corporation intended to become an S corporation on a specified date, but it did not timely file Form…
PLR 1030021: Inadvertent S corporation election failure excused
The IRS granted relief to a corporation whose S corporation election was not signed by every shareholder. The omitted signature belonged to an estate administrator, because the shareholders believed…
PLR 1030019: Late S corporation election relief granted with consistency conditions
The IRS granted a corporation relief for its late election to be treated as an S corporation. The corporation intended the election to be effective on a specified date but did not file it on time.…
PLR 1030018: S corporation status preserved after stock-class and passive-income issues
The IRS granted a corporation relief under section 1362(f) after identifying two possible problems with its S corporation status. Its stock had disparate preemptive rights that could have created a…
PLR 1030006: Late S corporation election relief granted
The IRS granted a corporation relief for failing to timely file its election to be treated as an S corporation. The corporation intended the election to be effective on a specified date and…
PLR 1030002: Inadvertent S election defect cured after unsigned shareholder consent
The IRS granted relief to a corporation whose S corporation election was ineffective because an estate administrator had not signed the election. The corporation and its shareholders believed that…
PLR 1030001: Late S corporation election relief granted
The IRS granted a corporation relief for failing to timely file its election to be treated as an S corporation. The corporation intended the election to be effective on a specified date and…
PLR 1029017: IRS grants late-election relief for S corporation status
A corporation intended to elect S corporation status for federal tax purposes but did not timely file the election. The IRS concluded that the corporation had established reasonable cause for the…
PLR 1029015: Rental income from managed residential properties is not passive investment income
A corporation planning to elect S corporation status asked whether rental income from residential properties owned by its subsidiary would be passive investment income. The corporation and its…
PLR 1029010: IRS grants late entity-classification and S corporation election relief
A limited liability company asked for more time to elect classification as an association taxable as a corporation and to file a late S corporation election. The company had intended both elections…
PLR 1029005: The IRS restored an S corporation election after an inadvertent trust-election failure
The IRS determined that a corporation’s S corporation election terminated inadvertently after three trusts received its stock and their beneficiaries failed to make the required Qualified Subchapter…
PLR 1029001: The IRS granted relief for a late S corporation election
The IRS found that a corporation had reasonable cause for failing to timely file its S corporation election. The corporation’s sole shareholder intended the election to be effective on the…
PLR 1028028: The IRS granted relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The corporation showed reasonable cause for the late election and otherwise had to…
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.