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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IRS grants more time to make an LLC's section 754 election
The IRS granted a limited liability company 120 more days to make a § 754 election for the year a member died. The company had inadvertently failed to make the election on time, but represented that…
IRS grants more time to make a partnership basis election
The IRS granted a limited partnership 120 more days to make a § 754 election for the year a partner died. The partnership had inadvertently failed to make the election on time, but represented that…
PLR 1352008: IRS grants extra time for a section 754 election
The IRS granted a partnership an additional 120 days to make a late election under IRC § 754 for a specified taxable year. The election became relevant after a new member acquired an interest in an…
Grantor trusts are disregarded for attribution and loss limitation analysis
Chief Counsel addressed the federal tax treatment of grantor trusts in a structure involving a limited liability company, related partnerships, and multiple trusts. The advice concluded that grantor…
PLR 1341002: IRS grants late section 754 election relief to a family partnership
The IRS granted a family limited partnership 120 additional days to make a section 754 election for Year 1 after the partnership's tax advisor failed to explain that the election was available. A…
PLR 1329003: IRS treats a tribal corporation investment arrangement as a partnership
The IRS ruled that a corporation formed under section 17 of the Indian Reorganization Act was not a separate entity from the federally recognized tribe that organized it for federal tax purposes.…
CCA 1326014: A planned transaction converts QSubs and disregarded entities and creates gain or loss on later stock sales
The Chief Counsel's Office analyzed a planned restructuring involving an S corporation, its qualified subchapter S subsidiaries, disregarded entities, partnerships, and buyers. It concluded that…
PLR 1326007: New bonds qualify as refunding bonds after partnership technical termination
The IRS ruled that new bonds issued to refinance existing bonds remained refunding bonds even though ownership purchases and a technical termination of a partnership occurred within six months of…
IRS recommends sale treatment for a leveraged partnership transaction
Chief Counsel Advice analyzes a leveraged partnership transaction involving an S corporation, contributed assets, intercompany notes, a bank loan, guarantees, and an indemnity. The memo recommends…
CCA 1323015: Collaboration is a partnership and cannot elect out of subchapter K
The IRS analyzed a collaboration between two corporations that developed and commercialized a product. It concluded that the collaboration was a partnership for federal tax purposes because the…
CCA 1319021: Partnership income follows the partnership tax year
Chief Counsel Advice addresses which parent corporation should report partnership income covered by a settlement agreement when the parent changed during one partner's tax year. The advice states…
CCA 1315026: New partnership continues the old partnership after a merger
Chief Counsel advice addresses whether a new partnership continued an original partnership for purposes of appointing a tax matters partner. The transaction involved a merger with a disregarded…
PLR 1314013: IRS grants more time to make a partnership basis election
A partnership asked for more time to make a § 754 election after a partner transferred an interest and the partnership failed to file the required short-year return. The election can adjust the…
PLR 1314004: IRS treats canceled partner notes as a cash distribution
A partnership made loans to one of its partners and documented them with notes. The partnership planned to cancel some of those notes and make a pro rata distribution to another partner to prevent…
PLR 1308019: IRS approves tax treatment for banks contributing life-insurance policies to a partnership
The IRS considered a plan in which banks would contribute permanent, cash-value life-insurance policies to a partnership in exchange for partnership interests. The IRS ruled that the contributions…
PLR 1251004: IRS grants extra time for a section 754 election
The IRS granted a limited liability limited partnership 120 days to make a late section 754 election. The partnership had failed to make the election for the year in which a member died. The IRS…
PLR 1250012: IRS grants extra time to make a section 754 election
The IRS granted a partnership an additional 120 days to make a section 754 election. The partnership had timely filed its tax return but omitted the written election statement required to adjust the…
PLR 1244004: IRS approves liquidating-trust and partnership-termination treatment
A limited partnership sold its assets and wanted to distribute the proceeds and dissolve, but it faced known and possible contingent liabilities. It formed a trust to hold cash, resolve those…
IRS advice limits an identified straddle loss to a partner's distributive share
The Office of Chief Counsel considered a U.S. holding company's treatment of identified straddle losses from a foreign partnership. The taxpayer argued that IRC § 1092(d)(4)(C) allowed it to treat…
PLR 1240008: IRS grants more time to make a section 754 election
A partnership asked for an extension of time to make a section 754 election after filing its tax return without the election. The election can adjust the basis of partnership property after certain…
IRS advice on partnership status and TEFRA treatment
Chief Counsel advice discusses whether an arrangement should be treated as a partnership for federal tax purposes. The advice explains that federal law controls, and that the parties' agreement,…
PLR 1222012: IRS grants more time to make a section 754 election
The IRS granted a limited liability company more time to make a section 754 election for the taxable year in which a partner died. The election had been omitted from the partnership return even…
PLR 1216019: IRS permits aggregate § 704(c) allocations after a partnership merger
Two partnerships treated as securities partnerships for federal tax purposes planned an assets-over merger. One used a full-netting method and the other used a partial-netting method for reverse…
PLR 1214006: IRS grants more time to make a section 754 election
The IRS considered a limited partnership's request for more time to make a section 754 election after interests in the partnership were sold and transferred. The partnership's tax advisors had not…
PLR 1213024: IRS grants 120 days to make a late section 754 election
The IRS granted a partnership 120 days to make a late election under IRC § 754 for a specified taxable year. The partnership's tax adviser had inadvertently failed to make the election on time after…
PLR 1213006: IRS grants extra time for a section 754 election
The IRS granted a limited partnership 120 days to make a late section 754 election for the specified year. Transfers of partnership interests had caused a technical termination, but the partnership…
PLR 1201014: IRS grants partnership 120 days to make a section 754 election
The IRS granted a state limited partnership 120 days to make a late election under IRC section 754. The partnership had timely filed its tax return but inadvertently omitted the election to adjust…
PLR 1201007: IRS grants more time for a late section 754 election
The IRS granted a partnership 120 days to make a late IRC § 754 election. The partnership had timely filed its tax return but inadvertently did not include the election to adjust the basis of…
PLR 1151014: IRS grants time to make a late Section 754 election
The IRS granted a partnership an additional 60 days to make an IRC § 754 election after two members acquired another member's interest. The partnership had timely filed its return but inadvertently…
PLR 1151011: IRS grants time to make a late Section 754 election
The IRS granted a limited partnership an additional 60 days to make a late IRC § 754 election to adjust the basis of partnership property. The partnership had filed later returns consistent with the…
IRS granted more time for a section 754 election
The IRS granted a partnership 120 days to make a late section 754 election to adjust the basis of partnership property. The partnership return had been timely filed, but the election was…
IRS granted more time for a section 754 election
The IRS granted a partnership 120 days to make a late section 754 election to adjust the basis of partnership property. The partnership return had been timely filed, but the election was…
IRS approves tax treatment for annuity termination and partnership-interest sale
The IRS approved the requested tax treatment for two trusts that planned to transfer partnership interests to a buyer in exchange for terminating life annuity contracts and receiving cash. The…
PLR 1135021: IRS grants more time for a partnership to make a late § 754 election
The limited liability company asked for more time to make a § 754 election after a transaction caused a termination under § 708(b)(1)(B). The election would allow adjustments to the basis of…
PLR 1129030: IRS grants more time for a section 754 election
An entity that began as a disregarded limited liability company later became a partnership and then underwent a technical termination under section 708(b)(1)(B). It inadvertently failed to make a…
PLR 1129024: Partnership granted more time to make a section 754 election
A limited liability company became a partnership and later underwent a technical termination, but it failed to file a section 754 election with its return. The partnership represented that it relied…
PLR 1127004: IRS approves a multi-step corporate reorganization and partnership treatment
A publicly traded parent company proposed a multi-step restructuring involving a wholly owned subsidiary and a partnership holding one of the subsidiary's business lines. The subsidiary would…
PLR 1122015: IRS grants more time for a partnership basis election
The IRS granted a partnership an extension of time to make an election under IRC § 754. The partnership had timely filed its return, but the election to adjust the basis of partnership property was…
PLR 1122011: IRS grants an extension for a late section 754 election
The IRS granted a limited liability company treated as a partnership an extension of time to make an election under IRC § 754. The company's return was filed without the election after a member…
PLR 1119020: partnership may make a late section 754 election
A partnership asked for more time to make an IRC § 754 election after filing its return without the election. The election would allow basis adjustments for certain partnership distributions and…
PLR 1116010: IRS granted time to make a section 754 election
The IRS considered a partnership that failed to timely make a section 754 election after one partner sold an interest to another person. The partnership represented that it relied on tax advisers,…
IRS grants extra time for a partnership’s section 754 election
The IRS granted a partnership 120 additional days to make a section 754 election. The partnership had resulted from a merger and later admitted new investors, but it inadvertently failed to make the…
PLR 1114011: IRS grants 120 days to make a late section 754 election
The IRS granted a limited liability company 120 days to make a late election under IRC § 754 for the tax year in which a member died. The company had inadvertently missed the deadline for the…
PLR 1108023: Partnership granted more time to make a section 754 election
The IRS granted a partnership an extension of time to make a section 754 election. The partnership had timely filed its return but failed to include the election, which can allow basis adjustments…
PLR 1104025: IRS grants more time to make a section 754 election
A partnership asked for more time to make a section 754 election after an inadvertent omission. A related entity had made a distribution in liquidation of a member's interest, and the resulting…
PLR 1103029: Partnership receives more time to make a section 754 election
A limited liability company asked for more time to make a section 754 election after experiencing a technical termination under section 708(b)(1)(B). The entity had inadvertently failed to make a…
PLR 1103018: Debt restructuring will not be treated as a disguised sale
A real estate investment trust with liabilities exceeding the value of its assets proposed to restructure its debt through a partnership and a related limited liability company. The transaction…
PLR 1103013: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. The IRS concluded that the…
PLR 1103012: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. The IRS concluded that the…
PLR 1103011: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. 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.