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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Seven foreign entities received more time to elect partnership status
Seven foreign eligible entities intended to be classified as partnerships for federal tax purposes but did not file Form 8832 for their intended effective dates. Each entity asked for an extension…
Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but failed to file Form 8832 on time. The IRS concluded that the entity met the standards for regulatory…
Foreign entity received 120 days to make a late disregarded-entity election
A foreign eligible entity failed to timely file Form 8832 to be treated as disregarded from its single owner for federal tax purposes. The IRS found that the entity satisfied the standards for…
Foreign entity gets more time to elect partnership status
A foreign limited liability partnership that is eligible to choose how it is classified for U.S. federal tax purposes wanted to be treated as a partnership effective a specific date. To make that…
Foreign entity gets more time to elect disregarded-entity status
A foreign business entity that is eligible to choose how it is classified for U.S. federal tax purposes wanted to be treated as a "disregarded entity" (that is, ignored as separate from its single…
Entity received more time to elect corporate tax classification
An eligible business entity intended to be treated as an association taxable as a corporation but did not timely file Form 8832. The entity represented that it acted reasonably and in good faith and…
Foreign entity received 120 days for late disregarded-entity election
A foreign eligible entity intended to elect treatment as an entity disregarded from its owner but did not timely file Form 8832. The IRS concluded that the entity satisfied the standards for…
Company received 120 days for late foreign disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its sole owner but inadvertently missed the deadline for filing Form 8832. The entity represented that it acted reasonably and in…
Foreign company received 120 days to file Form 8832
A foreign company intended to elect disregarded-entity treatment from a specified date but failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and that…
Foreign entity received 120 days for late corporate classification election
A foreign eligible entity intended to elect association status, making it taxable as a corporation for U.S. federal tax purposes, but failed to file Form 8832 for the intended effective date. Based…
Foreign entity received relief for late partnership election
A foreign eligible entity intended to elect partnership classification but inadvertently failed to timely file Form 8832. After a member died and the estate was administered, the entity became…
LLC could change early to disregarded entity status
A limited liability company had elected to be taxed as a corporation and wanted to change to disregarded entity status less than 60 months later. A new owner had acquired more than 50 percent of the…
LLC received relief for late corporate classification election
A single-owner limited liability company intended to be taxed as a corporation from its formation date but did not timely file Form 8832. Without the election, the company was disregarded as…
Foreign entity received more time to elect disregarded status
A foreign single-owner eligible entity became relevant for U.S. tax purposes with a default classification as an association taxable as a corporation. It intended to change to disregarded-entity…
Foreign entity received 120 days for a late corporate-classification election
A foreign eligible entity had initially elected disregarded-entity status and later intended to be classified as an association taxable as a corporation, but it did not timely file Form 8832 for the…
Five acquired entities could change to disregarded status within 60 months
A buyer acquired a corporation whose five domestic eligible entities had previously elected corporate classification, and the buyer and seller made Section 338(h)(10) elections for the acquisition.…
Foreign entity received 120 days to elect corporate classification
A foreign eligible entity intended to be classified as an association taxable as a corporation but did not timely file Form 8832 with the requested effective date. The IRS found that the entity…
LLC received 120 days to file a late corporate-classification election
A domestic limited liability company intended to be classified as a corporation from a specified date but did not timely file Form 8832. Based on the submitted facts and representations, the IRS…
Two foreign entities received late partnership-classification relief
Two foreign eligible entities whose default classifications were associations were owned by a married couple who later became U.S. tax residents. After one spouse died, the surviving spouse became…
Litigation-related extension did not end liquidating trust status
A liquidating trust was created under a Chapter 11 reorganization plan to convert assets to cash, resolve claims, and distribute proceeds to beneficiaries. Unresolved litigation had already required…
LLC received 120 days to make a late disregarded-entity election
A limited liability company had previously elected to be taxed as a corporation. It later intended to change its classification and become disregarded from its owner for federal tax purposes, but it…
LLC received an extension to change to disregarded-entity status
A limited liability company had elected corporate tax treatment and later intended to become disregarded from its owner. It inadvertently missed the deadline to file the required Form 8832 for the…
Late disregarded-entity election received a 120-day extension
A limited liability company had elected to be taxed as a corporation and later intended to change to disregarded-entity treatment. It inadvertently did not file Form 8832 by the deadline for the…
LLC was allowed to file a late disregarded-entity election
A limited liability company had chosen corporate tax status and later intended to elect disregarded-entity treatment. It inadvertently missed the Form 8832 filing deadline for the desired effective…
Corporate-classified LLC received more time to elect disregarded status
A limited liability company had elected to be classified as a corporation for federal tax purposes. It later intended to become disregarded from its owner but inadvertently failed to make the Form…
LLC received 120 days to elect disregarded-entity treatment
A limited liability company had elected to be treated as a corporation and later planned to change to disregarded-entity status. The company inadvertently did not file the classification election by…
Foreign entity received more time to elect disregarded status
A foreign entity represented that it was eligible to be disregarded as separate from its owner for federal tax purposes but failed to file Form 8832 on time. The IRS concluded that the requirements…
Foreign entity received 120 days to elect disregarded status
A foreign entity represented that it was eligible to be treated as disregarded from its owner but failed to file Form 8832 by the deadline. The IRS concluded that the requirements for regulatory…
Foreign entity received 120 days to elect disregarded status
A foreign entity represented that it was eligible to be treated as disregarded from its owner but failed to file Form 8832 by the deadline. The IRS concluded that the requirements for regulatory…
Late partnership classification election allowed
A foreign private company represented that it was an eligible entity that could elect partnership classification for U.S. federal tax purposes. It inadvertently failed to file Form 8832 on time for…
Limited partnership received 120 days to make a late corporate classification election
A limited partnership intended to elect treatment as an association taxable as a corporation but did not timely file Form 8832. It represented that it acted reasonably and in good faith and that…
Extension granted for foreign entity's disregarded status election
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes but did not timely file Form 8832. The IRS found that the entity satisfied the standards…
Mortgage certificate exchange trust qualifies as fixed investment trust
A mortgage-backed securities sponsor proposed exchange trusts that would hold one class of REMIC or grantor trust certificates. Investors could exchange those certificates for matching classes with…
Foreign company may make a late partnership election
A foreign private limited company intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The IRS found that the company met the standards for…
Early change to disregarded status permitted
A limited liability company had elected S corporation status, which caused it to be classified as an association taxable as a corporation. A new owner later acquired more than half of the company…
Foreign entity receives late disregarded election relief
A foreign eligible entity intended to be disregarded from its owner for U.S. federal tax purposes from its formation date but inadvertently failed to file Form 8832 on time. The entity was eligible…
Foreign-government investment partnership was not classified as a corporation
Two foreign-government controlled corporations formed a general partnership to pool investments, including possible investments in U.S. real property holding corporations. The partnership had at…
Foreign-government limited partnership was not classified as a corporation
A foreign-government asset manager used a limited partnership to pool investments for several public-sector investors. The partnership had a general partner and four limited partners, had elected…
Large foreign-government investment partnership was not a corporation
A foreign-government asset manager formed a limited partnership with a general partner and twelve limited partners to pool public-sector investments. Several investors were represented to be…
Foreign entity receives more time to elect partnership classification
A foreign entity represented that it was eligible to elect partnership treatment for federal tax purposes but failed to timely file Form 8832. It requested discretionary relief under Treasury…
LLC allowed to change from corporation to disregarded entity
A limited liability company had elected to be taxed as a corporation and later wanted to change to disregarded-entity status before the usual 60-month waiting period expired. A new owner had…
IRS grants a foreign entity 120 days to make a late "check-the-box" election to be disregarded
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A single-owner entity can elect to be "disregarded," meaning it is ignored for federal…
IRS gives an LLC 120 more days to elect corporation ("check-the-box") tax status it missed
A business converted from a state corporation into a state LLC and wanted to keep being taxed as a corporation, which requires filing Form 8832 (the "check-the-box" election). It missed the filing…
IRS gives three foreign entities 120 more days to elect to be disregarded for U.S. tax purposes
A foreign business entity with a single owner can elect, under the "check-the-box" rules, to be disregarded as separate from its owner for U.S. federal tax purposes (so its income and assets are…
IRS lets an entity change its tax classification to a partnership inside the normal 60-month lock-out after an ownership change
When a business entity elects to change how it is taxed (its "check-the-box" classification), it normally cannot elect to change again for 60 months. There is an exception: the IRS may allow an…
LLC gets 120 more days to elect corporation treatment after missing the Form 8832 deadline
A limited liability company wanted to be treated as a corporation for federal tax purposes. Under the "check-the-box" rules in Treasury Regulation section 301.7701-3, an eligible entity makes that…
Foreign entity received 120 days to elect partnership classification
A foreign eligible entity wanted to be classified as a partnership for federal tax purposes from its formation date but did not timely file Form 8832. The IRS concluded that the entity met the…
LLC receives relief for late corporate-classification and S corporation elections
An LLC intended to be classified as an association taxable as a corporation and to elect S corporation status from the same effective date, but it filed neither Form 8832 nor Form 2553. Based on the…
LLC receives 120 days for a late corporate-classification election
A limited liability company intended to be classified as an association taxable as a corporation from its requested effective date but failed to timely file Form 8832. Based solely on the submitted…
Foreign-owned LLC receives 120 days for a late corporate-classification election
A domestic LLC wholly owned by a foreign proprietary limited company intended to be classified as an association taxable as a corporation from its formation date. After converting between two…
Foreign entity receives 120 days for late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for federal tax purposes but failed to file Form 8832 on time. It asked for relief under the regulatory-election…
LLC receives 120 days for late corporate-classification election
A domestic limited liability company intended to elect association status so it would be taxed as a corporation from a specified date. It inadvertently failed to file Form 8832 on time. The company…
Government retiree health trust receives four favorable rulings
An association of state boards of education created a trust to fund medical, dental, and vision benefits for its retired employees. The IRS had previously ruled that the association performed…
LLC received 120 days to file a late corporate classification election
A single-owner limited liability company intended to be classified as an association taxable as a corporation from its formation date. Its default federal classification was a disregarded entity,…
LLC gets 120 days to file late corporate classification election
A domestic limited liability company intended to be classified as an association taxable as a corporation from a redacted effective date. It failed to file Form 8832 on time because of inadvertence…
Late check-the-box election to be taxed as a corporation allowed under 9100 relief
A limited liability company wanted to be classified as a corporation for federal tax purposes (an "entity classification," or "check-the-box," election) effective on a chosen date, but it missed the…
9100 relief for a foreign entity's late check-the-box election to be a partnership
A foreign business entity wanted to be treated as a partnership for U.S. federal tax purposes. Under the "check-the-box" rules (Treas. Reg. § 301.7701-3), an eligible entity can choose its tax…
Foreign entity gets late-election relief to be taxed as a corporation
A foreign business entity meant to be treated as a corporation for U.S. tax purposes from the day it was formed, which requires filing Form 8832 (an "entity classification" or "check-the-box"…
LLC gets late-election relief to be taxed as a corporation
A single-member LLC, wholly owned by a corporation, meant to elect to be treated as an association taxable as a corporation for federal tax purposes (rather than being disregarded, which is the…
Two foreign subsidiaries receive late disregarded-entity election relief
A foreign parent owned two foreign eligible entities that each intended to elect disregarded-entity status from its formation date but missed the Form 8832 deadline. The IRS concluded that both…
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.