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 200624043: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624042: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624041: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624040: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624039: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624038: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624037: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624036: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624035: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624034: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624033: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624032: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624031: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624030: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624029: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624028: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624027: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624026: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624025: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624024: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624023: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624022: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624021: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624020: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624019: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624018: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624017: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624016: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624015: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624014: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624013: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624012: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624011: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624010: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624009: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624008: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624007: Foreign entity may make late partnership election
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective on its incorporation date. It did not file Form 8832 on time and requested relief under the…
PLR 200624006: LLC receives more time to elect corporate tax treatment
A domestic limited liability company intended to be taxed as a corporation from a specified date but missed the deadline to file Form 8832. It requested a late election under the rules for…
PLR 200624005: Mortgage certificate classes qualify as strips in a fixed investment trust
A sponsor proposed a passive trust that would hold mortgage pass-through certificates or REMIC regular interests and issue several classes of certificates dividing the underlying principal and…
PLR 200624004: Division of family trust preserves GST exemption without gain or gift tax
Trustees proposed to divide a family trust into two successor trusts, one for each of two daughters and her family, while preserving the surviving spouse's interest in both. They represented that…
PLR 200624003: Division of family trust preserves GST exemption without gain or gift tax
Trustees proposed to divide a family trust into two successor trusts, one for each of two daughters and her family, while preserving the surviving spouse's interest in both. They represented that…
CCA 200624002: Virgin Islands return alone does not start the IRS assessment period
Chief Counsel considered a U.S. citizen who filed a tax return with the U.S. Virgin Islands but failed at least one condition for the special treatment in § 932(c)(4). That treatment requires bona…
PLR 200624001: Corporate contribution and spinoff qualify as a D reorganization
A corporate group planned to separate one business from its other businesses after a proposed merger. The parent would transfer subsidiaries and assets to a controlled company for stock, securities,…
PLR 200623077: Late recharacterization allowed after corrected wage income invalidates Roth conversion
A taxpayer converted two traditional IRAs to a Roth IRA while believing the couple's modified adjusted gross income was below the then-applicable $100,000 conversion limit. A later corrected wage…
PLR 200623076: IRA rollover deadline waived after broker's alleged misappropriation
A taxpayer withdrew money from an IRA to make an investment through a broker who told him it would be held in an IRA. He said funds were misappropriated and that he could not complete the rollover…
Determination 200623075: Automobile down payment program denied charity status
A nonprofit sought recognition as a § 501(c)(3) charity for a program that used money from participating car dealers to help buyers make down payments. The dealers referred buyers, set aside funds…
Determination 200623074: Seller-funded home down payment program denied charity status
A nonprofit sought § 501(c)(3) recognition for a home down payment assistance program funded primarily by sellers whose homes were sold through the program. Assistance was open without an income…
Determination 200623072: IRS proposes revoking skydiving club's social club exemption
An exempt skydiving club trained and served members and the general public. Its examination report said student and other nonmember receipts were 41% and 46% of income in two years, well above the…
Determination 200623071: Seller-funded down payment program denied charity status
A nonprofit sought § 501(c)(3) recognition for a home down payment assistance program operated with a related organization and a marketing company. The program had no income limit, and home sellers…
PLR 200623069: Foreign investment income will not create unrelated business taxable income for trust
A charitable remainder trust planned to invest through a partnership in a foreign corporation that would invest in securities and other financial instruments. The foreign corporation's underlying…
PLR 200623068: Farm education foundation receives advance ruling on public charity transition
A private operating foundation that preserved a historic farm and offered agricultural education sought to end its private foundation status. It expected broader donations and membership support…
PLR 200623067: Foundation may set aside funds for senior facility construction
A private foundation planned to build a senior facility but had faced a property dispute and still needed approvals related to its construction plans. It asked to set aside income so cash would be…
PLR 200623066: Hospitalization warrants waiver of Roth IRA rollover deadline
A taxpayer withdrew funds from a Roth IRA intending to move them to another Roth IRA with a higher yield. She instead deposited the funds in a regular money market account and underwent hip…
PLR 200623065: Bank miscommunication warrants IRA rollover deadline waiver
A taxpayer took a distribution from an IRA intending to move it into a safer IRA at another financial institution. After speaking with a bank representative, she assumed the bank's affiliated…
PLR 200623064: LLC receives time to file corporate classification and S corporation elections
An LLC's records showed that it intended to be taxed as an S corporation, but there was no record that it timely filed either its entity classification election or its S corporation election. The…
CCA 200623063: Penalties for church programs disguising tuition as donations
Church members paid amounts that covered private school tuition through their churches, while the churches issued contribution statements saying the members received nothing in return. Chief Counsel…
PLR 200623062: Foreign entity receives extension to elect disregarded status
A foreign entity's owner said the entity was eligible to be treated as disregarded for U.S. tax purposes and had intended that classification from a specified date. The entity did not file Form 8832…
CCA 200623061: Rules for repeat church examinations and who may authorize an inquiry
Chief Counsel considered whether the IRS could monitor a church after an examination found political campaign intervention without revoking its exemption. Counsel said staff could review publicly…
CCA 200623060: Unposted return is a missed assessment, not an erroneous abatement
A taxpayer's return and tax were posted to the wrong tax year. IRS staff reversed that posting and sent the return for reprocessing, but it never posted to the correct year before the assessment…
PLR 200623059: Foreign entity may file late partnership classification election
A foreign entity intended to elect partnership treatment for U.S. federal tax purposes from the date it was incorporated. It did not file the required Form 8832 on time. The IRS concluded that 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.