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 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 1032017: Multi-step spin-offs and merger reorganized related business lines
A publicly traded holding company proposed separating several business lines through three internal spin-offs and two internal split-offs. It would then contribute the separated businesses to a…
PLR 1032016: Two transfers of U.S. real property interests qualify for nonrecognition
A nonresident individual proposed two related transfers involving shares of domestic corporations and an interest in a disregarded limited liability company that held U.S. real property interests.…
PLR 1032015: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032014: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032013: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032012: IRS granted late-election relief for partnership classification
A foreign eligible entity intended to elect partnership classification for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted…
PLR 1032011: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032010: Qualified disclaimer supports charitable estate tax deduction
A decedent's daughter proposed disclaiming her interest in specified trust assets that would otherwise pass to her trust. The assets would instead pass to a foundation recognized by the IRS as a…
PLR 1032009: Bankruptcy merger treated as a section 368(a)(1)(G) reorganization
A corporate holding company and its subsidiaries entered bankruptcy under title 11 with substantial secured and unsecured debt. Under an approved bankruptcy plan, the holding company would merge…
PLR 1032008: IRS granted time to correct an incomplete entity election
A foreign eligible entity filed an incomplete Form 8832 when it intended to elect disregarded-entity status for federal tax purposes. The IRS found that the requirements for relief under Treas. Reg.…
PLR 1032007: IRS granted time to file a late entity election
A foreign entity inadvertently failed to timely file Form 8832, Entity Classification Election. The IRS concluded that the requirements for relief under Treas. Reg. § 301.9100-3 were satisfied…
PLR 1032006: IRS granted time to file a late disregarded-entity election
A foreign entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1032005: IRS granted time to correct an entity election date
A foreign entity filed Form 8832 but used an incorrect effective date for its disregarded-entity election. The entity represented that it had consistently been treated as disregarded for federal tax…
PLR 1032004: IRS granted time to file a late disregarded-entity election
A foreign entity whose default classification was an association taxable as a corporation intended to elect disregarded-entity status but failed to timely file Form 8832. The IRS concluded that the…
PLR 1032003: Securities partnership may use full-netting allocation method
A partnership classified as a securities partnership held actively traded securities contributed by pension-plan, VEBA, and regulated-investment-company owners. It used the full-netting approach to…
PLR 1032002: Qualified disclaimer supports charitable estate tax deduction
A decedent's daughter proposed disclaiming her interest in specified trust assets that would otherwise pass to her trust. The assets would instead pass to a foundation recognized by the IRS as a…
PLR 1032001: IRS granted time to make a late section 754 election
A partnership inadvertently failed to timely make a section 754 election after an ownership interest was acquired. The IRS concluded that the partnership acted reasonably and in good faith and that…
PLR 1031043: IRS approved a governmental excess benefit arrangement for contributions exceeding section 415 limits
The IRS approved a governmental excess benefit arrangement for a hospital district's governmental pension plan. The arrangement would hold employer contributions that could not be made to the…
PLR 1031042: IRS approved rollover treatment for a final pension payment after funding improves
The IRS ruled that the final payment of a participant's elected pension lump sum could qualify as an eligible rollover distribution if the plan became sufficiently funded within the represented…
PLR 1031041: IRS waived the 60-day rollover deadline after an investment manager misdirected an IRA distribution
The IRS waived the 60-day rollover requirement for a taxpayer whose IRA distribution was mistakenly deposited into a joint non-IRA brokerage account. The taxpayer had instructed an investment…
PLR 1031040: IRS waived the 60-day rollover deadline after an adviser failed to establish an IRA
The IRS waived the 60-day rollover requirement for a taxpayer whose retirement-plan distribution was deposited into a non-IRA account after a financial adviser failed to establish the requested IRA.…
PLR 1031039: IRS waived the 60-day rollover deadline after misleading financial advice
The IRS waived the 60-day rollover requirement for a taxpayer who withdrew funds from two IRA annuities and deposited the proceeds into a taxable account. The taxpayer said a financial adviser…
PLR 1031038: IRS waived the 60-day rollover deadline after a financial institution opened a nonqualified account
The IRS waived the 60-day rollover requirement for a 78-year-old taxpayer whose IRA distribution was deposited into a nonqualified taxable account. The taxpayer intended to move the funds into…
Determination 1031037: IRS approved a foundation's set-aside for a historic-building matching grant
The IRS approved a private foundation's set-aside for a matching grant to a publicly supported charitable organization. The grant would help restore a historically and architecturally significant…
Determination 1031036: IRS approved investment fees for a private foundation despite founder control
The IRS ruled that an investment trust and its funds were not disqualified persons with respect to a private foundation. The foundation's founder controlled its board and also owned and controlled…
Determination 1031035: IRS denied a group ruling request to reclassify subordinate clubs under section 501(c)(3)
The IRS denied a national organization's request to modify its group ruling so that its subordinate clubs would qualify under IRC § 501(c)(3). The organization and its clubs conducted charitable and…
Determination 1031034: IRS denied exemption to a senior membership organization operating social trips and celebrations
The IRS denied tax-exempt status under IRC § 501(c)(3) to a membership organization for seniors. The organization held holiday celebrations, dinners, and sightseeing trips for members, and most of…
Determination 1031033: IRS denied a national organization's request for section 501(c)(3) exemption
The IRS denied a national organization's request for recognition under IRC § 501(c)(3). The organization conducted youth development and charitable programs, but the IRS concluded that its…
Determination 1031032: IRS denied exemption to a proposed school with incomplete operations and financial information
The IRS denied exemption under IRC § 501(c)(3) to a proposed school for students with learning disabilities or attention deficit disorder. The applicant had not begun operating, had not held board…
PLR 1031031: IRS granted an extension to elect corporate tax classification for an LLC
The IRS granted a limited liability company an extension of time to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC had defaulted to partnership status…
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 1031029: IRS granted an extension to elect disregarded-entity 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 disregarded entity for U.S. income tax purposes. The entity had inadvertently failed to file the…
PLR 1031028: IRS granted an extension to elect partnership 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 partnership for U.S. income tax purposes. The entity had inadvertently failed to file the…
PLR 1031027: 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 1031026: 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 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 1031021: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031020: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031019: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031018: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031017: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031016: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031015: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
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 1031013: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031012: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031011: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
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 1031009: IRS granted an extension to group rental real estate interests
The IRS granted married taxpayers an extension of time to elect to treat all of their rental real estate interests as one rental real estate activity. They had filed a joint return without the…
PLR 1031008: IRS granted an extension to group rental real estate interests
The IRS granted a taxpayer an extension of time to elect to treat all rental real estate interests as one rental real estate activity. The taxpayer qualified under the real property business…
PLR 1031007: IRS treated commodity-linked note income as qualifying RIC income
The IRS ruled that income and gain from three described commodity-linked notes would be qualifying income for a regulated investment company under IRC § 851(b)(2). The fund planned to invest in the…
PLR 1031006: IRS granted an extension to make a section 754 election
The IRS granted a partnership an extension of time to make a valid IRC § 754 election. The partnership had transferred partnership interests but filed its return without a valid election to adjust…
PLR 1031005: IRS granted an extension to make a section 754 election
The IRS granted a partnership an extension of time to make a valid IRC § 754 election. The partnership had transferred partnership interests but filed its return without a valid election to adjust…
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 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…
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.