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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 200636081: Foreign company receives more time for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636080: Foreign entity receives filing extension for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636079: Foreign company receives filing extension for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636078: Foreign entity gets extension for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636077: Foreign company gets more time for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636076: Foreign entity gets more time for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636075: Foreign company gets filing extension for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636074: Foreign entity receives late election relief for disregarded status
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636073: Foreign entity receives more time for disregarded status election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636072: Foreign company receives late Form 8832 relief
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636071: Foreign entity gets more time to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636070: Foreign company gets late Form 8832 filing relief
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636069: Foreign entity gets late Form 8832 filing relief
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636068: Foreign company receives extension for late Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636067: Foreign entity receives extension for late Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636066: Foreign company receives more time to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636065: Foreign entity gets more time for Form 8832 election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636064: Foreign company receives more time for Form 8832 election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636063: Foreign entity receives more time for Form 8832 election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636062: Foreign company gets more time for Form 8832 election
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636061: Foreign entity receives filing extension for Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636060: Foreign company gets extension to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636059: Foreign entity gets extension to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636058: Foreign company gets extension to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636057: Foreign entity gets extra time to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636056: Foreign company gets extra time to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636055: Foreign entity gets extra time to file Form 8832
A foreign entity came under a single owner's control and intended to be treated as disregarded for federal tax purposes from that acquisition date. It did not file Form 8832 on time to make the…
PLR 200636054: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636053: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636052: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636051: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636050: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636049: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636048: Foreign entity gets more time for its classification election
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It missed the deadline to file Form 8832…
PLR 200636047: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636046: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636045: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636044: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636043: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636042: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636041: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636040: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636039: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636038: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636037: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636036: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636035: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636034: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636033: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636032: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636031: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636030: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636029: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636028: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636027: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636026: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636025: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636024: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636023: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
PLR 200636022: Foreign entity gets more time to elect disregarded status
A foreign entity acquired a single owner with limited liability and intended to be treated as disregarded for federal tax purposes from the acquisition date. It did not file Form 8832 on time. The…
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.