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 200623058: Foreign entity allowed late election for partnership treatment
A foreign entity was incorporated with the intention of electing partnership treatment for U.S. federal tax purposes from its formation date. It failed to file Form 8832 by the normal deadline. The…
PLR 200623057: Late partnership election permitted for foreign entity
A foreign entity intended to file Form 8832 to be treated as a partnership for U.S. tax purposes from its incorporation date, but missed the filing deadline. The IRS concluded that the entity…
PLR 200623056: Foreign company gets time to elect partnership tax status
A foreign entity said it had intended to file Form 8832 to elect partnership classification for U.S. federal tax purposes, effective when it was incorporated. It missed the filing deadline. The IRS…
PLR 200623055: Late Form 8832 allowed for foreign partnership classification
A foreign entity wanted partnership classification for U.S. federal tax purposes from its incorporation date but did not file Form 8832 on time. The IRS concluded that it met the requirements for…
PLR 200623054: Filing deadline extended for foreign entity's partnership election
A foreign entity intended to elect partnership treatment for U.S. federal tax purposes from its incorporation date. It did not timely file Form 8832. The IRS concluded that the entity met the…
PLR 200623053: Foreign entity granted more time for partnership election
A foreign entity planned to elect partnership classification for U.S. federal tax purposes from its incorporation date, but Form 8832 was not filed on time. The IRS found that the entity satisfied…
PLR 200623052: Partnership classification election may be filed late
A foreign entity intended to be treated as a partnership for U.S. federal tax purposes from the date it was incorporated, but did not file Form 8832 on time. Based on the entity's submissions, the…
PLR 200623051: Late partnership election accepted for foreign entity
A foreign entity intended to elect partnership classification for U.S. federal tax purposes from its incorporation date. Its Form 8832 was not filed by the normal deadline. Based on the information…
PLR 200623050: Foreign entity receives filing extension for partnership election
A foreign entity wanted partnership classification for U.S. federal tax purposes effective on its incorporation date, but it missed the Form 8832 filing deadline. The IRS found that the entity…
PLR 200623049: More time granted for foreign entity's partnership tax election
A foreign entity said it intended to be classified as a partnership for U.S. tax purposes from its incorporation date, but failed to file the required Form 8832 on time. The IRS concluded that the…
PLR 200623048: Foreign entity gets late partnership election relief
A foreign entity was formed with the intention of electing partnership status for U.S. federal tax purposes effective on its incorporation date. It missed the deadline for Form 8832. The IRS…
PLR 200623047: Foreign partnership tax election receives late filing relief
A foreign entity intended to file Form 8832 to elect partnership treatment for U.S. federal tax purposes beginning on its incorporation date. It did not file on time. The IRS found that the entity…
PLR 200623046: Late Form 8832 permitted for partnership tax classification
A foreign entity incorporated with the intention of electing partnership treatment for U.S. federal tax purposes. Its Form 8832 was not filed on time. The IRS found that the entity met the standards…
PLR 200623045: Foreign entity may file Form 8832 after deadline
A foreign entity intended to elect partnership tax classification effective on its incorporation date but missed the Form 8832 deadline. The IRS found that the entity satisfied the standards for…
PLR 200623044: Deadline extended for foreign entity's partnership classification
A foreign entity planned to elect partnership classification for U.S. federal tax purposes from its incorporation date but filed no timely Form 8832. The IRS concluded that the entity met the…
PLR 200623043: Late partnership election granted for foreign entity
A foreign entity intended to elect partnership status for U.S. federal tax purposes from its incorporation date, but missed the Form 8832 deadline. Based on the entity's submissions, the IRS…
PLR 200623042: Partnership election deadline extended for foreign entity
A foreign entity intended partnership classification for U.S. federal tax purposes from its incorporation date but missed the Form 8832 deadline. The IRS concluded that the entity qualified for…
PLR 200623041: Late partnership classification election approved
A foreign entity wanted partnership classification for U.S. federal tax purposes from the date it was incorporated. It did not file Form 8832 on time. The IRS concluded that the entity met the…
PLR 200623040: Foreign entity allowed late partnership tax election
A foreign entity intended to file Form 8832 to be treated as a partnership for U.S. federal tax purposes from its incorporation date, but the election was not timely filed. The IRS determined that…
PLR 200623039: Foreign entity gets 60 days for late partnership election
A foreign entity planned to elect partnership tax treatment from its incorporation date but failed to timely file Form 8832. The IRS found that the entity satisfied the requirements for…
PLR 200623038: Late foreign partnership classification election allowed
A foreign entity intended to be treated as a partnership for U.S. federal tax purposes from its incorporation date but missed the Form 8832 filing deadline. The IRS found that the entity met the…
PLR 200623037: Foreign partnership election deadline relief granted
A foreign entity intended to elect partnership classification for U.S. federal tax purposes effective when it was incorporated. Its Form 8832 was not filed on time. The IRS found that the…
PLR 200623036: Late Form 8832 partnership election permitted
A foreign entity intended to be classified as a partnership for U.S. federal tax purposes from the date it was incorporated but did not timely file Form 8832. The IRS found that the entity satisfied…
PLR 200623035: Foreign entity gets extension for partnership classification
A foreign entity intended to elect partnership status for U.S. federal tax purposes effective on its incorporation date, but it failed to file Form 8832 on time. The IRS found that the entity…
PLR 200623034: More time allowed for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification effective from its incorporation date but did not file Form 8832 by the usual deadline. The IRS concluded that the entity satisfied…
PLR 200623033: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623032: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623031: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623030: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623029: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623028: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623027: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623026: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623025: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623024: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623023: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623022: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623021: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623020: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623019: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623018: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623017: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623016: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623015: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623014: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623013: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623012: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623011: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623010: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623009: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623008: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623007: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623006: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623005: More time granted for foreign entity's partnership election
A foreign entity intended to elect partnership tax classification from its incorporation date, but did not file Form 8832 on time. The IRS concluded that the entity met the requirements for…
PLR 200623004: Extra time granted to submit dual consolidated loss documents
A corporation sought more time to attach documents to its Year 5 income tax return. The documents were intended to rebut a presumption that sales of two entities triggered recapture of dual…
PLR 200623003: State required escrow accounts qualify as settlement funds
A product manufacturer placed money in escrow accounts required by state laws to address claims related to its products. The IRS ruled that the accounts became qualified settlement funds on a…
PLR 200623002: Foreign entity receives time to elect partnership classification
A foreign entity said it was eligible to elect partnership classification when it was formed, but inadvertently missed the Form 8832 filing deadline. The IRS found that it satisfied the standards…
CCA 200623001: Sole proprietor claims health insurance deduction on Form 1040
Chief Counsel clarified where a sole proprietor claims the self-employed health insurance deduction. The advice says that section 162(l) allows the deduction, subject to its limits, even when the…
PLR 200622059: Hospital reorganization preserves exemption and supporting status
A tax-exempt pediatric hospital proposed to absorb the assets and activities of two related organizations that would dissolve. A third organization would continue fundraising and investment…
PLR 200622058: Hospital receives three conditional pension funding waivers
A hospital and its health system faced cash flow problems after patient volume fell and they lost medical staff. The IRS changed the conditions on an earlier minimum funding waiver for 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.