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.
IRS grants 30 days to file missing LIFO election forms
The IRS granted a parent company an extension to file Forms 970 for two newly formed subsidiaries that had adopted the last-in, first-out inventory method. The parent had transferred assets and…
Foreign entities receive more time to elect partnership classification
The IRS granted eight foreign entities 120 additional days to file valid Forms 8832 electing to be treated as partnerships for federal tax purposes. The entities had intended to use partnership…
IRS grants 60 days to recharacterize a failed Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a failed SEP IRA to Roth IRA conversion as a contribution to a traditional IRA. The taxpayer exceeded the income limit for the Roth IRA…
IRS grants 60 days to recharacterize a failed Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a failed SEP IRA to Roth IRA conversion as a contribution to a traditional IRA. The taxpayer exceeded the income limit for the Roth IRA…
IRS grants extra time to make an IC-DISC election
A domestic corporation intended to operate as an interest charge domestic international sales corporation, or IC-DISC, but its Form 4876-A election was not timely filed. The taxpayer said its…
Foreign entities granted extra time to elect corporation status
The IRS granted seven foreign entities an extension of time to file Form 8832 entity-classification elections. The entities had failed to timely file valid elections to be classified as corporations…
Taxpayer granted extra time to elect current deduction of drilling costs
The IRS granted a taxpayer 120 additional days to make an election under IRC § 263(c) to deduct intangible drilling and development costs. The taxpayer's disregarded LLC had incurred those costs,…
LLC granted extra time to elect corporation classification
The IRS granted a domestic LLC 120 additional days to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC's members had intended the election to be…
Early replacement S corporation election denied
An S corporation asked for permission to make a new S election before the five-year waiting period following termination of its prior election. The corporation had transferred shares to an…
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…
PLR 1352005: IRS grants extra time to elect an extended net operating loss carryback
The IRS granted a consolidated corporate group 60 days to make a late election extending the carryback period for a consolidated net operating loss. The group missed the election deadline after…
PLR 1352004: late entity classification election
The ruling concerns a foreign eligible entity that failed to timely elect partnership classification for federal tax purposes. The entity later became wholly owned by a corporation, which caused it…
PLR 1351016: consolidated group gets extra time to elect an NOL carryback
A consolidated corporate group missed the deadline to elect an extended carryback period for a consolidated net operating loss. The group said it reasonably relied on a qualified tax professional…
PLR 1351015: IC-DISC receives extra time to file its election
A domestic corporation formed to operate as an interest charge domestic international sales corporation, or IC-DISC, failed to file the required shareholder-consented Form 4876-A election for its…
PLR 1351012: IC-DISC election treated as timely after filing problem
A corporation formed to operate as an interest charge domestic international sales corporation, or IC-DISC, mailed its Form 4876-A election but later learned that the IRS service center had no…
PLR 1351011: taxpayer gets extra time to file Forms 3115
A taxpayer timely filed its federal return and duplicate Forms 3115 to change its depreciation accounting method, but an accounting firm accidentally failed to attach the original Forms 3115 to the…
PLR 1351010: foreign insurer receives extra time for a section 953(d) election
A foreign corporation intended to elect under IRC § 953(d) to be treated as a domestic corporation for U.S. tax purposes, but it could not locate the signed election and later determined that the…
PLR 1351007: taxpayers receive extra time to elect out of GST exemption automatic allocation
Two spouses made gifts to irrevocable trusts that held life insurance policies and later benefited their children and descendants. They did not elect out of the generation-skipping transfer tax…
PLR 1350003: IRS grants extra time to elect disregarded-entity classification
The IRS granted a foreign, wholly owned entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the…
PLR 1350002: IRS grants extra time to elect disregarded-entity classification
The IRS granted a foreign, wholly owned entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the…
PLR 1349028: Company gets 60 days to make a late qualified-separate-line election
A parent company and its subsidiary maintained separate lines of business and wanted the subsidiary treated as a qualified separate line of business for employee-plan testing. Their benefits…
PLR 1349009: IRS grants more time for a consolidated group’s extended NOL carryback election
The IRS granted a consolidated group 90 days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline and represented…
PLR 1349008: IRS grants more time for a consolidated group’s NOL carryback election
The IRS granted a consolidated group 60 days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline and represented…
PLR 1349005: IRS grants more time to divide a reverse-QTIP trust
An estate had made a QTIP election, a reverse QTIP election, and an allocation of generation-skipping transfer tax exemption to a marital trust. After the filing, a regulation allowed certain trusts…
PLR 1349003: IRS grants extra time to elect IC-DISC status
A domestic corporation intended to elect IC-DISC status for its first taxable year but did not timely file Form 4876-A. The taxpayer attributed the missed filing to a misunderstanding between its…
PLR 1348008: IRS grants a trust more time to make a section 663(b) election
A trust mistakenly filed its federal income tax return using a fiscal year instead of the calendar year. It intended to make a section 663(b) election for distributions credited to beneficiaries…
PLR 1348004: IRS grants a foreign entity more time to elect disregarded-entity status
A foreign entity wholly owned by one person was eligible to elect to be treated as a disregarded entity for federal tax purposes, but it did not file Form 8832 by the applicable deadline. The IRS…
PLR 1348003: IRS grants a foreign entity more time to elect partnership status
A foreign entity owned by two persons was eligible to elect partnership classification for federal tax purposes, but it did not file the required entity classification election on time. The IRS…
PLR 1348002: IRS grants a foreign entity more time to elect disregarded-entity status
A foreign entity wholly owned by one person was eligible to elect to be treated as a disregarded entity for federal tax purposes, but it did not file the entity classification election on time. The…
IRS grants an extension for an IC-DISC election
The IRS granted a domestic corporation an extension of time to file Form 4876-A and make an election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The…
IRS grants late-filing relief for a Form 1128 accounting-period change
The IRS treated a corporation's late Form 1128 as timely filed for a requested change in its federal tax year. The corporation sought to change its year end from June 30 to September 30 and filed…
IRS grants more time for a tax-exempt controlled entity election
The IRS granted a 60-day extension for a taxpayer to make an election under section 168(h)(6)(F)(ii), which concerns whether a tax-exempt controlled entity will be treated as tax-exempt for…
PLR 1347011: IRS grants a 45-day extension for a late consolidated-return election
A corporate parent and three subsidiaries missed the deadline to elect to file a consolidated federal income tax return. The parent asked the IRS for relief under the regulations that allow extra…
PLR 1347008: IRS grants 120 days to make a late foreign-entity partnership election
A foreign eligible entity missed the deadline to file Form 8832 electing partnership classification for federal tax purposes. The entity asked for relief under the regulations that permit an…
PLR 1347006: IRS grants 60 days to make a late IC-DISC election
A domestic corporation formed to operate as an interest charge domestic international sales corporation, or IC-DISC, missed the deadline to file Form 4876-A. Its accounting firm gave it the wrong…
PLR 1347004: IRS grants 60 days to make a late investment-income election
A taxpayer missed the deadline to elect under section 163(d)(4)(B)(iii) to treat certain net capital gains from investment property as investment income. The missed election affected the taxpayer's…
PLR 1346008: IRS grants extra time for a Canadian RRSP treaty election
The IRS granted a married couple an extension of time to elect treaty treatment for undistributed income accrued in their Canadian RRSPs. The couple had moved to the United States, timely filed U.S.…
PLR 1346003: IRS grants extra time for an IC-DISC election
The IRS granted a corporation a 60-day extension to file Form 4876-A and make an IC-DISC election for its first taxable year. The corporation had been formed for that purpose, but its owners…
PLR 1345029: IRS grants extra time for a generation-skipping transfer election
The IRS granted an estate 120 extra days to elect out of the automatic allocation of generation-skipping transfer tax exemption to a gift made to one of two trusts. The taxpayers had instructed…
PLR 1345022: IRS grants extra time to elect partnership classification
A foreign private limited company asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The company was eligible to make the election but did not…
PLR 1345017: IRS grants extra time to allocate GST exemption to a trust
Two taxpayers created trusts for their children and intended to allocate generation-skipping transfer tax exemption to one trust. Their tax professional failed to make the intended allocation on a…
PLR 1345016: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345015: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345014: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345013: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345012: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345011: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345010: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345009: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345008: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345007: IRS grants extra time to elect partnership classification
A foreign business entity defaulted to corporate tax classification because its members had limited liability, but it intended to be treated as a partnership for federal tax purposes. The entity…
PLR 1345002: Entity receives more time to elect partnership classification
An eligible foreign entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under the…
PLR 1344006: IRS grants extra time to elect out of bonus depreciation
A parent company requested extra time to elect not to claim additional first-year depreciation for qualified property placed in service during a specified tax year. Its accounting firm omitted the…
PLR 1344005: IRS grants extra time for a consolidated group to elect an extended NOL carryback
A consolidated corporate group incurred a consolidated net operating loss and missed the deadline to elect an extended carryback period. The group requested relief after discovering that the…
PLR 1344003: IRS grants extra time to file Form 3115 for repair-cost accounting changes
A consolidated taxpayer intended to use the automatic accounting-method change procedure for repair and maintenance costs that did not need to be capitalized. Its accounting firm filed Form 3115…
PLR 1344002: IRS grants extra time to file Form 3115 with an amended return
A taxpayer electronically filed a consolidated corporate return but accidentally omitted the original Form 3115 required for an accounting-method change involving repair and maintenance costs. After…
PLR 1344001: IRS grants extra time to file Form 3115 with a partnership return
A taxpayer electronically filed Form 1065 but accidentally omitted the original Form 3115 required for an accounting-method change involving repair and maintenance costs. After discovering the…
PLR 1343017: extension granted for a treaty election involving a Canadian retirement plan
The IRS revoked and replaced an earlier private letter ruling for a U.S. resident who had contributed to a Canadian registered retirement savings plan. The taxpayer had not made the election under…
PLR 1343015: late IC-DISC election granted an extension
The IRS considered a domestic corporation that filed Form 4876-A late and with incomplete information for an election to be treated as an interest charge domestic international sales corporation, or…
PLR 1343014: Canadian RRSP treaty election extension granted
The IRS considered a married couple who had moved from Canada to the United States while continuing to hold Canadian registered retirement savings plans. Their accountant had not told them to file…
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.