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.

10,617 determinations and counting · Newest release July 31, 2026
10,617 determinations

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DET

Business district group denied § 501(c)(6) exemption for providing member website services

A business district organization sought exemption as a business league or similar organization under § 501(c)(6). It promoted district events, ran sidewalk sales, and maintained a website where member…

202611013·March 13, 2026
Denied
DET

Member-owned water company denied § 501(c)(3) exemption for serving private interests

A mutual benefit corporation sought § 501(c)(3) status for supplying and testing water from a shared well. It delivered water only to member-owned parcels, collected monthly member payments for usage …

202611012·March 13, 2026
Denied
DET

IRS denies veterans organization exemption because too few members are war veterans

An organization supporting veterans, active-duty service members, and their families applied for exemption under IRC Section 501(c)(19). Its membership included current or former members of the Armed …

202611011·March 13, 2026
Denied
DET

IRS denies 501(c)(3) exemption to a class reunion and scholarship group

An organization open only to graduates of one high school class applied for recognition as a charity under IRC Section 501(c)(3). It arranged reunions and other events for class members and raised mon…

202611010·March 13, 2026
Denied
CCA

Chief Counsel advises issuing an FPA despite a missed NAP mailing

Chief Counsel advised the IRS to proceed with issuing an FPA even though the NAP had not been mailed to the LKA. The advice gave two reasons. First, the writer concluded that the BBA does not provide …

202611009·March 13, 2026
Advice
PLR

Partnership gets 60 more days to self-certify as a qualified opportunity fund

A partnership formed to invest in qualified opportunity zone property intended to elect qualified opportunity fund status. Its accountant knew of that intent but failed to advise the partnership to fi…

202611008·March 13, 2026
Approved
PLR

Foreign entity gets 120 days to file a late check-the-box election

A foreign entity intended to be treated as disregarded from its single owner for U.S. federal tax purposes but did not timely file Form 8832. It asked the IRS for an extension under Treasury Regulatio…

202611007·March 13, 2026
Approved
PLR

Estate gets 120 days to make a late portability election

An estate was not otherwise required to file an estate tax return but needed Form 706 to transfer the decedent's unused estate and gift tax exclusion to the surviving spouse. The estate did not timely…

202611006·March 13, 2026
Approved
PLR

Foreign entity gets 120 days to make a late disregarded-entity election

A foreign entity intended to be treated as disregarded from its owner for U.S. federal tax purposes but inadvertently failed to timely file Form 8832. It requested an extension under Treasury Regulati…

202611005·March 13, 2026
Approved
PLR

IRS grants more time to elect treaty sourcing for gain on foreign stock

A U.S. consolidated group sold stock in a foreign corporation and paid tax to the foreign country on the gain. The group reported the gain as U.S.-source income after its original return preparer did …

202611004·March 13, 2026
Approved
PLR

IRS grants an LLC more time to elect corporate tax classification

An LLC intended to be taxed as a corporation from the date it was formed but inadvertently failed to file Form 8832 on time. The entity asked for relief under Treasury Regulation Section 301.9100-3, w…

202611003·March 13, 2026
Approved
PLR

IRS approves a downstream merger as a Type A reorganization

An S corporation proposed to merge downstream into a corporation whose stock was its primary asset, leaving the lower-tier corporation as the survivor. The S corporation's shareholders would receive n…

202611002·March 13, 2026
Approved
PLR

IRS grants a late safe-harbor election for acquisition success fees

An S corporation incurred a success-based advisory fee through disregarded subsidiaries in a taxable business acquisition. Its original return preparer did not advise it to make the safe-harbor electi…

202611001·March 13, 2026
Approved
PLR

IRS approves a pension plan's use of plan-specific substitute mortality tables for three plan years under § 430(h)(3)(C)

A company that sponsors a single-employer defined benefit pension plan asked the IRS for permission to use its own plan-specific mortality tables, instead of the standard tables in the regulations, wh…

202610022·March 6, 2026
Approved
DET

IRS gives advance approval of a private foundation's high-school scholarship procedures under § 4945(g)(1)

A private foundation asked the IRS to approve, in advance, the way it selects and awards scholarships to graduating high school students of a particular school. Private foundations owe an excise tax o…

202610021·March 6, 2026
Approved
DET

IRS denies § 501(c)(3) exemption to a winter-sports social club that fails the organizational and operational tests

A newly formed ski and winter-sports club applied for recognition as a tax-exempt charity under Code section 501(c)(3), using the short Form 1023-EZ. The IRS denied the application and, after the club…

202610020·March 6, 2026
Denied
DET

IRS denies § 501(c)(6) business-league exemption to a single-brand franchisee association

A group of franchisees who all own outlets of one particular brand formed an association and applied for tax exemption as a "business league" under Code section 501(c)(6). The IRS denied the applicati…

202610019·March 6, 2026
Denied
DET

IRS denies § 501(c)(6) exemption to a commercial condominium owners' association

An owners' association for a commercial (business) condominium applied for tax exemption as a "business league" under Code section 501(c)(6). The association manages the building's common areas, handl…

202610018·March 6, 2026
Denied
DET

IRS denies § 501(c)(3) exemption to a homeowners' association serving private member interests

A homeowners' association, organized as a mutual benefit common-interest development corporation, applied for charitable tax exemption under Code section 501(c)(3) using Form 1023-EZ. Its activities a…

202610017·March 6, 2026
Denied
PLR

IRS grants a foreign entity extra time to make a late check-the-box election to be a disregarded entity

A foreign business entity wanted to be treated as a "disregarded entity" for U.S. federal tax purposes, meaning it is ignored as separate from its single owner (its income flows directly to that owner…

202610016·March 6, 2026
Approved
PLR

IRS grants a partnership extra time to make a late § 754 basis-adjustment election

A limited partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its property when a partner transfers an interest or receives a distribution. That adjustm…

202610015·March 6, 2026
Approved
PLR

IRS rules on nuclear decommissioning trust transfers in a partial sale of a nuclear power plant

Two owners of a nuclear power plant restructured their stakes. A private seller (a disregarded subsidiary of a taxable parent) is selling part of its undivided ownership interest in the plant to a buy…

202610014·March 6, 2026
Approved
PLR

IRS grants a corporate parent extra time to make a late election to file a consolidated return

The parent company of an affiliated group of corporations wanted the group to file a single consolidated federal income tax return, with the parent as the common parent, for a particular tax year. Tha…

202610013·March 6, 2026
Approved
PLR

IRS grants a new corporate parent extra time to make a late consolidated-return election after an acquisition

A holding company (an LLC that elected to be taxed as a corporation), formed by private equity funds to buy a target corporation, acquired that target through its subsidiary. The target had been the c…

202610012·March 6, 2026
Approved
PLR

IRS grants an estate extra time to make a late portability election under § 2010(c)(5)(A)

When someone dies, any unused portion of their federal estate-and-gift tax exclusion can be passed to their surviving spouse through a "portability" election. This is valuable because it lets the surv…

202610011·March 6, 2026
Approved
PLR

IRS grants a foreign insurer extra time to make a late § 953(d) election to be treated as a domestic corporation

A foreign regulated insurance company was bought by a U.S. corporate group. Under section 953(d), certain foreign insurance companies can elect to be treated as domestic (U.S.) corporations for tax pu…

202610010·March 6, 2026
Approved
PLR

Late § 754 election allowed for a partnership after two partners died

A partnership missed the deadline to make a § 754 election and asked the IRS for more time. A § 754 election lets a partnership adjust the tax basis of its assets when a partner's interest changes han…

202610009·March 6, 2026
Approved
PLR

Late § 754 election allowed for an LLC taxed as a partnership

An LLC taxed as a partnership meant to make a § 754 election but did not file it on time with its return. A § 754 election lets a partnership adjust the tax basis of its assets when interests change h…

202610008·March 6, 2026
Approved
PLR

Late estate-tax portability election allowed for a surviving spouse

When a married person dies without using all of their federal estate-tax exemption, the leftover amount (the deceased spousal unused exclusion, or DSUE) can be passed to the surviving spouse, but only…

202610007·March 6, 2026
Approved
PLR

Late estate-tax portability election allowed for a surviving spouse

A married person died leaving part of their federal estate-tax exemption unused. That leftover amount (the deceased spousal unused exclusion, or DSUE) can be transferred to the surviving spouse, but o…

202610006·March 6, 2026
Approved
PLR

Late § 336(e) election allowed to treat an S-corp stock sale as an asset sale

When someone buys all the stock of an S corporation, the parties can elect under § 336(e) to treat the deal as if the company sold all its assets and liquidated, which usually gives the buyer a steppe…

202610005·March 6, 2026
Approved
PLR

Late election allowed to treat a trust as a GST trust and allocate exemption

The generation-skipping transfer (GST) tax is a separate transfer tax that applies when wealth skips a generation, but each person has a GST exemption they can allocate to shelter gifts from it. A gra…

202610004·March 6, 2026
Approved
PLR

State Medicaid in-home care payments are excludable difficulty-of-care payments

A state Medicaid agency runs an in-home supportive care program that pays individual caregivers to look after disabled or chronically ill people who would otherwise need a nursing home or other instit…

202610003·March 6, 2026
Approved
PLR

Tax-free split-off letting one family branch take its own corporation

A publicly traded corporation, owned mostly by three related families plus other shareholders, wants to divide up its main business. It will form a new subsidiary, drop part of the business into it, a…

202610002·March 6, 2026
Approved
PLR

Inadvertent S-corp terminations excused after trusts missed QSST and ESBT elections

An S corporation can only have certain kinds of shareholders. When a shareholder dies and stock passes to a trust, the trust can hold it for a two-year grace period, but to keep it longer the trust (o…

202610001·March 6, 2026
Approved
PLR

Late set-aside election allowed on an amended Form 8609 for the low-income housing credit

The low-income housing credit under § 42 rewards owners who rent a share of their units to lower-income tenants. To qualify, an owner must pick a "minimum set-aside" test on Form 8609, and once made t…

202609015·February 27, 2026
Approved
PLR

Late check-the-box election allowed for a foreign entity 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 foreign entity can elect to be "disregarded," meaning it is ignored as a sep…

202609014·February 27, 2026
Approved
PLR

Late election allowed to apportion a consolidated § 382 limitation to departing members

When companies that had losses leave a consolidated group, the group's parent can elect under Treas. Reg. § 1.1502-95(c) to hand off part of the group's § 382 limitation (the annual cap on using pre-o…

202609013·February 27, 2026
Approved
PLR

Late check-the-box election allowed for a foreign entity to be disregarded

Under the "check-the-box" rules, an eligible business entity can pick how it is taxed by filing Form 8832. A single-owner foreign entity can elect to be "disregarded," meaning it is ignored as a separ…

202609012·February 27, 2026
Approved
PLR

Late Form 8996 accepted, allowing an LLC to self-certify as a qualified opportunity fund

A qualified opportunity fund (QOF) is an investment vehicle under § 1400Z-2 that lets investors defer capital gains by putting them into designated low-income "opportunity zones." To be a QOF, an enti…

202609011·February 27, 2026
Approved
PLR

Late Form 8996 accepted, allowing an LLC to self-certify as a qualified opportunity fund

A qualified opportunity fund (QOF) is an investment vehicle under § 1400Z-2 that lets investors defer capital gains by reinvesting them in designated low-income "opportunity zones." An entity self-cer…

202609010·February 27, 2026
Approved
PLR

Late check-the-box election allowed for a domestic LLC to be taxed as a corporation

Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. By default a domestic LLC with two or more members is a partnership (or, with a single owne…

202609009·February 27, 2026
Approved
PLR

Late § 108(b)(5) election allowed to reduce depreciable-property basis first for cancelled debt

When a company's debt is forgiven, it normally has taxable cancellation-of-debt income, but an insolvent company can exclude that income under § 108 in exchange for cutting its tax attributes (things …

202609008·February 27, 2026
Approved
PLR

Late check-the-box election allowed for a foreign entity to be disregarded

Under the "check-the-box" rules, an eligible business entity can pick how it is taxed by filing Form 8832. A single-owner foreign entity can elect to be "disregarded," so it is ignored as a separate t…

202609007·February 27, 2026
Approved
PLR

Late estate-tax portability election allowed for a surviving spouse

A married person died leaving part of their federal estate-tax exemption unused. That leftover amount (the deceased spousal unused exclusion, or DSUE) can pass to the surviving spouse, but only if the…

202609006·February 27, 2026
Approved
PLR

Late Form 8996 accepted, allowing an LLC to self-certify as a qualified opportunity fund

A qualified opportunity fund (QOF) is an investment vehicle under § 1400Z-2 that lets investors defer capital gains by reinvesting them in designated low-income "opportunity zones." An entity self-cer…

202609005·February 27, 2026
Approved
PLR

Late Form 8996 accepted, allowing an LLC to self-certify as a qualified opportunity fund

A qualified opportunity fund (QOF) is an investment vehicle under § 1400Z-2 that lets investors defer capital gains by reinvesting them in designated low-income "opportunity zones." An entity self-cer…

202609004·February 27, 2026
Approved
PLR

Late check-the-box election allowed for two LLCs to be taxed as corporations

Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. By default a domestic LLC with two or more members is a partnership (or, with one owner, is…

202609003·February 27, 2026
Approved
PLR

Inadvertent S-corp termination excused after a trust missed its ESBT election

An S corporation can only have certain kinds of shareholders. A trust can qualify if it makes an electing small business trust (ESBT) election, filed by the trustee. Here all the shares of an S corpor…

202609002·February 27, 2026
Approved
PLR

Late estate-tax portability election allowed for a surviving spouse

A married person died leaving part of their federal estate-tax exemption unused. That leftover amount (the deceased spousal unused exclusion, or DSUE) can pass to the surviving spouse, but only if the…

202609001·February 27, 2026
Approved
PLR

IRS pre-approves a foundation's scholarship-award procedures under § 4945(g)(1)

A private foundation asked the IRS to approve, in advance, the procedures for a scholarship program before it made any awards. Under IRC § 4945, scholarship grants a private foundation pays to individ…

202607024·February 13, 2026
Approved
DET

IRS denies § 501(c)(3) exemption to an open-source software organization

An organization that develops and distributes open-source software (tools and patches for mobile apps) applied for recognition as a tax-exempt charity under IRC § 501(c)(3), using the short Form 1023-…

202607023·February 13, 2026
Denied
DET

IRS revokes a private foundation's exemption for self-dealing loans to a founder's LLCs

The IRS revoked the tax-exempt status of a private foundation because it stopped operating for charitable purposes. On audit, the agency found the foundation's main activity was making loans to LLCs w…

202607022·February 13, 2026
Revocation
PLR

120-day extension for an LLC to file a late check-the-box election to be taxed as a corporation

A limited liability company wanted to be taxed as a corporation rather than under the default rules that treat an LLC as a partnership or a disregarded entity. To do that, it had to file Form 8832 (th…

202607021·February 13, 2026
Approved
PLR

120-day extension for a partnership to make a late § 754 basis-adjustment election

An LLC taxed as a partnership wanted to make a § 754 election, which lets a partnership adjust the tax basis of its assets when a partner's interest changes hands or property is distributed, so the ne…

202607020·February 13, 2026
Approved
PLR

120-day extension for a partnership to make a late § 754 basis-adjustment election

An LLC taxed as a partnership wanted to make a § 754 election, which lets a partnership adjust the tax basis of its assets when a partner's interest changes hands, so a buying partner's inside basis m…

202607019·February 13, 2026
Approved
PLR

60-day extension to file a missing § 174 R&E method-change statement with an amended return

A corporate group that files a consolidated return had to change its accounting method to comply with § 174 as amended by the 2017 Tax Cuts and Jobs Act, which requires research or experimental (SRE) …

202607018·February 13, 2026
Approved
PLR

Late S-corp election relief plus 9100 extension for a PLLC's corporate-classification election

A professional LLC intended to be taxed as an S corporation from the day it was formed. To get there, an LLC normally must both elect to be classified as a corporation (via Form 8832) and elect S-corp…

202607017·February 13, 2026
Approved
PLR

120-day extension for a foreign entity to file a late check-the-box election to be disregarded

A foreign business entity wanted to be treated as a disregarded entity for U.S. tax purposes, meaning it is ignored as separate from its single owner (so the owner reports the entity's income directly…

202607016·February 13, 2026
Approved
PLR

120-day extension for a foreign entity to file a late check-the-box election to be disregarded

A foreign business entity wanted to be treated as a disregarded entity for U.S. tax purposes, meaning it is ignored as separate from its single owner (so the owner reports the entity's income directly…

202607015·February 13, 2026
Approved

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.