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 200933019: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933018: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933017: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933016: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933015: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933014: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933013: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933012: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933011: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933010: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933009: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933008: LLC received more time to elect corporate tax treatment
The IRS considered a domestic limited liability company's late election to be treated as an association taxable as a corporation. The LLC was wholly owned, intended that classification from its…
PLR 200933007: Converted corporation received time to elect corporate classification
The IRS considered a state corporation's conversion to a state limited liability company and its failure to timely elect corporate classification for federal tax purposes. The LLC was wholly owned,…
PLR 200933006: Converted corporation received time to elect corporate classification
The IRS considered a state corporation's conversion to a state limited liability company and its failure to timely elect corporate classification for federal tax purposes. The LLC was wholly owned,…
PLR 200933005: Converted corporation received time to elect corporate classification
The IRS considered a state corporation's conversion to a state limited liability company and its failure to timely elect corporate classification for federal tax purposes. The LLC was wholly owned,…
PLR 200933004: Converted corporation received time to elect corporate classification
The IRS considered a state corporation's conversion to a state limited liability company and its failure to timely elect corporate classification for federal tax purposes. The LLC was wholly owned,…
PLR 200933003: State deferred compensation plan qualified for section 457 treatment
The IRS reviewed a deferred compensation plan sponsored by a state for its employees and participating political subdivisions. The plan allowed participants to defer compensation, included catch-up…
PLR 200933002: Fund-linked notes qualified for the portfolio interest exception
The IRS considered notes issued by a financial-services subsidiary to foreign investors. The notes paid a fixed amount plus a contingent amount based on the performance of shares in a foreign…
PLR 200933001: Partnership received time to make a section 754 election
The IRS considered a limited partnership that timely filed its return but inadvertently omitted a section 754 election after a partnership-property transaction. The election would adjust the basis…
IRS determination 200932060: Foundation's scholarship procedures received advance approval
The IRS gave a private foundation advance approval for its procedure to award scholarships to high school seniors in a defined geographic area. The selection criteria included academic performance,…
CCA 200932058: Jury verdict controls the character of compensatory damages
Chief Counsel advice addressed how to determine the character and purpose of a compensatory damage award. The advice states that the jury verdict controls that determination, even if the plan of…
CCA 200932057: Tax-return preparation documents generally are not privileged
Chief Counsel advice addressed attorney-client privilege and work-product protection for documents and information obtained to prepare a tax return. The advice states that tax-return preparation…
CCA 200932056: Extended due date controlled the start of the notification period
Chief Counsel advice addressed when an 18-month notification period should begin for purposes of section 6404(g). The return was mailed on October 15, 2002, the extended due date. The advice…
CCA 200932055: Counsel questions flat-rate valuation of airline buddy passes
Chief Counsel advice questioned the taxpayer's flat-rate valuation of airline buddy passes for round-trip, space-available flights. The email states that the regulations value a space-available…
CCA 200932054: Partnership's general partner had to execute a TEFRA extension
Chief Counsel advice addressed who could bind an entity when a tax matters partner signed an agreement extending the statute of limitations in a multiple-tier partnership case. The advice states…
CCA 200932053: Different remedies applied to two erroneous-refund cases
Chief Counsel advice addressed remedies for two erroneous refunds in a TEFRA partnership context. For the first case, the advice states that the government could bring an erroneous-refund suit…
CCA 200932052: State-law authority controlled who could sign for a partnership
Chief Counsel advice addressed who could sign for a partnership in a TEFRA matter. The advice states that the key question is whether the person or entity has authority under applicable state law to…
CCA 200932051: Inconsistent partner reporting could be assessed directly
Chief Counsel advice addressed section 704(c) allocations reported inconsistently by partners in a TEFRA case. The advice states that the allocations were partnership items, but a correct…
CCA 200932050: Public Law 110-172 added section 35 to the deficiency definition
Chief Counsel advice addressed when section 35 was added to the list of sections in section 6211(b)(4). The advice states that Public Law 110-172 added section 35. It explains that language…
CCA 200932049: Trust-preferred securities and their notes should be treated as debt
Chief Counsel advice considered whether a taxpayer's trust-preferred securities and underlying notes were debt or equity for federal income tax purposes. The advice applied the…
PLR 200932048: Parent receives more time to file a subsidiary stock loss election
The IRS granted an affiliated corporate group more time to file a statement election concerning a loss on the disposition of a subsidiary's stock. The stock became worthless within the meaning of…
PLR 200932047: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended that classification from its…
PLR 200932046: LLC receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign limited liability company 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The LLC intended that classification from…
PLR 200932045: Foreign company receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign limited company 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The company intended that classification from a…
PLR 200932044: Late Form 1128 is treated as timely filed
The IRS treated a group of taxpayers' late-filed Form 1128 as timely filed for a requested change in annual accounting period. The taxpayers attributed the late filing to intervening events beyond…
PLR 200932043: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended that classification from a specified…
PLR 200932042: Converted foreign company receives 60-day extension to elect corporate status
The IRS granted a foreign company 60 days to file Form 8832 and elect association status, which is treated as corporate status for federal tax purposes. The company was formed as a private limited…
PLR 200932041: Converted foreign company receives 60-day extension to elect corporate status
The IRS granted a foreign company 60 days to file Form 8832 and elect association status, which is treated as corporate status for federal tax purposes. The company was formed as a private limited…
PLR 200932040: Domestic entity receives 60-day extension to elect corporate status
The IRS granted a domestic eligible entity 60 more days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity was formed as a…
PLR 200932039: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity was formed under foreign law, and its owner intended…
PLR 200932038: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity was formed under foreign law, its owners had limited…
PLR 200932037: Partnership receives 60-day extension to make a section 754 election
The IRS granted a general partnership 60 days to make an election under IRC § 754. A partner had died, and the partnership's return for that year was filed without the election. The partnership…
PLR 200932036: Foreign entity receives 60-day extension to elect partnership status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended partnership treatment from its formation…
PLR 200932035: Foreign entity receives 60-day extension to elect partnership status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect partnership treatment for federal tax purposes. The entity intended that treatment from a specified effective date but…
PLR 200932034: Foreign subsidiary receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity was wholly owned through a parent-subsidiary chain and intended…
PLR 200932033: Nuclear plant owner receives approval of revised decommissioning schedule
The IRS approved a taxpayer's proposed revised schedule of ruling amounts for payments to a nuclear decommissioning reserve fund. The taxpayer requested a mandatory review after a public utility…
PLR 200932032: Nuclear plant owner receives approval of revised decommissioning schedule
The IRS approved a taxpayer's proposed revised schedule of ruling amounts for payments to a nuclear decommissioning reserve fund. The taxpayer requested a mandatory review after a public utility…
PLR 200932031: Corporation's inadvertent S election termination is excused
The IRS ruled that a corporation's S corporation election terminated when a revocable trust ceased to be an eligible shareholder after the deemed owner's death and the statutory two-year period. The…
PLR 200932030: Taxpayers receive more time for a qualified-residence interest election
The IRS granted taxpayers 60 days to make an election concerning debt secured by a qualified residence. The taxpayers had deducted interest on the loan as qualified residence interest and later…
PLR 200932029: Pro rata trust division does not trigger gain or loss
The IRS ruled on the federal income tax consequences of dividing a testamentary trust into five separate trusts. Each new trust would benefit one of the five living children of the original…
PLR 200932028: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign entity 60 days to file an election to be treated as a disregarded entity for federal tax purposes. The entity had a single owner on the specified effective date, making it…
PLR 200932027: Corporation receives relief for late S corporation election
The IRS found reasonable cause for a corporation's failure to timely file Form 2553 to elect S corporation treatment. The corporation intended the election to be effective on its registration date…
PLR 200932026: Unused GST exemption is automatically allocated to a trust
The IRS ruled on the allocation of a decedent's unused generation-skipping transfer tax exemption among trusts created before the 1986 GST tax rules took effect. The decedent's estate did not…
PLR 200932025: Entity receives 60-day extension to elect disregarded-entity status
The IRS granted an entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it was eligible to make the election on its specified…
PLR 200932024: Foreign entity receives 60-day extension to elect partnership status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect partnership treatment for federal tax purposes. The entity was eligible to make that election but inadvertently missed…
PLR 200932023: Foreign entity receives 60-day extension to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on a specified…
PLR 200932022: S corporation treatment continues after an inadvertent trust-related termination
The IRS ruled that a corporation's S corporation election terminated when a trust became an ineligible shareholder after the end of its permitted post-death period. The corporation represented that…
PLR 200932021: REIT's repayment of management fees reduces its gross income
The IRS ruled that a self-administered real estate investment trust's repayment of part of its property management fees to a joint venture was an adjustment to the price of its services, rather than…
PLR 200932020: Trust reformation preserves charitable remainder unitrust status and estate tax treatment
The IRS ruled that a court-approved reformation of a charitable remainder unitrust would not disqualify the trust when the reformation corrected a drafting error concerning the charitable remainder…
PLR 200932019: LLC receives 60-day extension to elect corporate tax treatment
The IRS granted a successor entity a 60-day extension to file Form 8832 and elect to be treated as a corporation for federal tax purposes. The entity had converted from a corporation to a limited…
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.