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 200903040: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903039: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903038: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903037: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903036: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903035: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903034: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903033: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903032: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903031: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903030: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903029: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903028: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903027: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903026: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903025: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903024: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903023: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903022: Foreign subsidiary received 60 days to elect disregarded status
A foreign corporation acquired another foreign corporation whose wholly owned subsidiary was also foreign. The parties intended the subsidiary to become disregarded for U.S. federal tax purposes…
PLR 200903021: Late Form 8832 relief for a foreign subsidiary swept up in an acquisition
A foreign company was the wholly owned subsidiary of another foreign corporation, and that parent was itself acquired by a third foreign corporation through an intermediate subsidiary. As part of…
PLR 200903020: Missed entity-classification election excused for a foreign subsidiary
A foreign entity was the wholly owned subsidiary of a foreign corporation that a second foreign corporation bought through an intermediate subsidiary. The buyer intended the subsidiary to be…
PLR 200903019: Sixty more days to elect disregarded status after an overlooked Form 8832
A foreign entity was owned entirely by a foreign corporation, and that corporation was acquired by another foreign corporation through an intermediate subsidiary. The plan was for the entity to be…
PLR 200903018: Acquired foreign entity allowed to file its disregarded-status election late
A foreign entity formed abroad was the wholly owned subsidiary of a foreign corporation, and a different foreign corporation acquired that parent through an intermediate subsidiary. Everyone…
PLR 200903017: Relief granted for a Form 8832 that an acquisition left unfiled
A foreign entity was wholly owned by a foreign corporation that was itself bought by another foreign corporation through an intermediate subsidiary. The buyer meant the entity to be disregarded for…
PLR 200903016: Foreign entity gets extra time to be treated as disregarded
An entity organized outside the United States was the sole subsidiary of a foreign corporation, and another foreign corporation acquired that parent through an intermediate subsidiary. The intent…
PLR 200903015: Inadvertent failure to file Form 8832 cured by a 60-day extension
A foreign entity was the wholly owned subsidiary of a foreign corporation that was acquired by a second foreign corporation through an intermediate subsidiary. Following the acquisition, the entity…
PLR 200903014: Late entity-classification election allowed after a cross-border acquisition
A foreign entity was the sole subsidiary of a foreign corporation, and that corporation was acquired by another foreign corporation through an intermediate subsidiary. After the deal, the entity was…
PLR 200903013: Overlooked Form 8832 does not cost a foreign entity its disregarded status
A company organized abroad was owned entirely by a foreign corporation, and a second foreign corporation acquired that owner through an intermediate subsidiary. The parties intended the company to…
PLR 200903012: Extension granted to elect disregarded treatment from the intended date
A foreign entity was the wholly owned subsidiary of a foreign corporation that another foreign corporation acquired through an intermediate subsidiary. The intent was for the entity to be…
PLR 200903011: Missed Form 8832 deadline forgiven for an acquired foreign subsidiary
A foreign entity was the wholly owned subsidiary of a foreign corporation, and that corporation was acquired by another foreign corporation through an intermediate subsidiary. From a chosen date…
PLR 200903010: Sixty days to fix an entity-classification election missed in a takeover
A foreign entity was owned outright by a foreign corporation that a second foreign corporation acquired through an intermediate subsidiary. The parties intended the entity to be disregarded for U.S.…
PLR 200903009: More time to file the election that makes a foreign subsidiary disregarded
A foreign entity was the wholly owned subsidiary of a foreign corporation, and another foreign corporation acquired that parent through an intermediate subsidiary. After the acquisition the entity…
PLR 200903008: Disregarded-entity election revived after an inadvertent filing failure
A foreign entity was the sole subsidiary of a foreign corporation that another foreign corporation bought through an intermediate subsidiary. From a chosen date after the deal, the entity was…
PLR 200903007: Section 9100 relief for a foreign entity's unfiled classification election
A foreign entity was wholly owned by a foreign corporation that a second foreign corporation acquired through an intermediate subsidiary. The plan was for the entity to be disregarded for U.S.…
PLR 200903006: Entity organized in one country, owners in another, gets late election relief
An entity formed under the law of one foreign country was the wholly owned subsidiary of a corporation from a second foreign country, and a corporation from that same second country acquired the…
PLR 200903005: Deadline extended for a cross-border subsidiary's disregarded-status election
An entity organized in one foreign country was the wholly owned subsidiary of a corporation organized in a second foreign country, and another corporation from that second country acquired the…
PLR 200903004: Foreign subsidiary allowed to file its Form 8832 after the fact
An entity formed in one foreign country was the wholly owned subsidiary of a corporation from a second foreign country, and a corporation from that second country acquired the parent through an…
PLR 200903003: Sixty-day window to elect disregarded treatment after an acquisition
An entity formed under the law of one foreign country was the wholly owned subsidiary of a corporation from a second foreign country, and another corporation from that second country acquired the…
PLR 200903002: Late Form 8832 accepted so a foreign entity can be disregarded
An entity organized in one foreign country was wholly owned by a corporation from a second foreign country, and a corporation from that same second country acquired the parent through an…
PLR 200903001: Critical illness rider benefits excludable under section 104(a)(3)
A stock life insurance company sells flexible premium adjustable life insurance policies. It attaches a rider that lets the policy owner accelerate part or all of the death benefit while the insured…
PLR 200902015: 60-day IRA rollover waived after a bank parked the money in the wrong account
Money taken out of an IRA is taxable unless it goes back into an IRA within 60 days. A 55-year-old taxpayer held two IRAs at two different institutions and wanted to consolidate both into a single…
PLR 200902014: Advance approval for a foundation's grants commissioning new musical works
A private foundation that pays grants to individuals normally owes an excise tax on them, because such grants count as "taxable expenditures" under section 4945(d)(3). There is an escape hatch:…
PLR 200902013: Formalizing a free-clinic partnership does not cost a hospital its exempt status
Two nonprofit hospitals, both already exempt under section 501(c)(3) and both classified as hospitals under sections 509(a)(1) and 170(b)(1)(A)(iii), had for years jointly run six free-standing…
PLR 200902012: Splitting a charitable remainder unitrust in a divorce triggers no foundation-level tax
A married couple had set up an irrevocable charitable remainder unitrust. It paid them a fixed percentage of the trust's value each year, split between them in quarterly installments, with the whole…
TAM 200902011: What counts as one property when hurricanes damage an electric utility's grid
An investor-owned electric utility was hit by two hurricanes in one year and a tropical storm the next. It spent heavily replacing poles, transformers and miles of wire, and claimed casualty loss…
PLR 200902010: Moving a grandfathered trust's securities into a partnership keeps its GST exemption
A trust that was already irrevocable on September 25, 1985 is grandfathered out of the generation-skipping transfer tax. That exemption is fragile: adding property to the trust, or modifying it in a…
PLR 200902009: Pre-1985 trust may hold its securities through a partnership without GST consequences
The generation-skipping transfer tax does not reach trusts that were already irrevocable on September 25, 1985. Keeping that shelter means not adding property to the trust and not modifying it in…
PLR 200902008: Trust with a guaranteed minimum payout keeps GST grandfathering after moving assets into a partnership
A trust that was already irrevocable on September 25, 1985 sits outside the generation-skipping transfer tax. That protection can be lost if property is added to the trust, or if the trust is…
PLR 200902007: A post-bankruptcy loss corporation may track its 5-percent owners from SEC Schedules 13D and 13G
Section 382 caps how much of its old losses a corporation can use after its ownership changes hands. Measuring that change means tracking who owns 5 percent or more of the stock, which is close to…
PLR 200902006: S election restored after shareholder trust lacked a valid ESBT election
An S corporation's election terminated on a redacted date because its stock was held by a trust whose trustee had failed to make a valid electing small business trust (ESBT) election. The…
PLR 200902005: Section 1362(f) relief for a corporation whose trust shareholder skipped the ESBT election
A trust that holds S corporation stock has to elect to be an electing small business trust. Being eligible is not enough, and no one else can make the election for the trustee. When the election is…
PLR 200902004: Missed ESBT election treated as an inadvertent termination of S status
Section 1362(f) is the statutory safety net for a botched S corporation election. It applies when an election was ineffective from the start or was terminated because the corporation stopped being a…
PLR 200902003: Corporation stays an S corporation despite its trust shareholder's unfiled ESBT election
Losing S corporation status is expensive and retroactive. The corporation becomes taxable in its own right from the date of the disqualifying event, its shareholders lose the pass-through treatment…
PLR 200902002: Inadvertent-termination relief granted, with the ESBT election due within 60 days
The corporation asked for one thing: a ruling under section 1362(f) that the termination of its S election was inadvertent. The termination happened because a trust held its stock and the trustee…
PLR 200902001: S election survives a trust beneficiary's missed QSST election
A trust can hold S corporation stock indefinitely only if it fits one of the permitted categories. Some trusts qualify automatically for a limited window after receiving the stock; once that window…
PLR 200901035: 60-day rollover waived where medical conditions left the taxpayer unable to manage his finances
Money taken out of an IRA is taxable unless it goes back into a retirement account within 60 days. Since 2002 the IRS has been able to waive that deadline when enforcing it would be against equity…
Determination 200901034: Exemption revoked for a seller-funded down payment assistance organization
The IRS revoked the tax-exempt status of an organization that gave home buyers the cash they needed for a down payment. The revocation is retroactive. The money moved in a circle. The organization…
CCA 200901033: Assumed medical liabilities yield section 162 deductions, not capital losses
A company pointed to a 1984 private letter ruling issued on an arrangement in which it had taken on responsibility for a set of medical liabilities. That ruling rested on three things sitting in…
CCA 200901032: Prepaid product payments are income on receipt without a valid deferral method
A seller let customers pay for a season of product deliveries up front, either as one lump sum or as equal installments spread across the season. Either way the customer locked in a fixed price per…
CCA 200901031: Lonely parent status does not shift to a former common parent for carrybacks
When a corporation brings losses into a consolidated group from years it filed on its own, those losses are usually capped. The rules call them separate return limitation year losses, or SRLY…
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.