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 1337004: S corporation receives more time to elect QSub status
An S corporation asked for extra time to elect to treat two wholly owned subsidiaries as qualified subchapter S subsidiaries, or QSubs, effective on an earlier date. The IRS found that the…
PLR 1336019: Private foundation receives more time to make a qualifying-distribution election
A private foundation inadvertently failed to attach a regulatory election to its Form 990-PF that would treat certain prior excess qualifying distributions as current distributions out of corpus.…
PLR 1336017: IRS grants a REIT an extension to make consent-dividend elections
A real estate investment trust and related entities asked for more time to make consent-dividend elections for prior tax years. The elections were needed to treat certain excess inclusion income…
PLR 1336014: IRS grants more time for a tax-exempt controlled entity to make an election
A tax-exempt organization wholly owned a corporation that served as managing general partner of a partnership developing affordable rental housing. The partnership received an energy-property…
PLR 1336013: IRS grants more time to elect IC-DISC status
A domestic corporation intended to be treated as an interest charge domestic international sales corporation, or IC-DISC, from its first taxable year. Its advisers prepared the required Form 4876-A,…
PLR 1336011: IRS grants more time to elect relief for a Canadian retirement plan
A U.S. citizen who had lived in Canada since childhood established a Canadian registered retirement savings plan and did not know that a U.S. election was needed for the plan. After learning that…
PLR 1336010: IRS grants more time to elect treaty relief for Canadian retirement accounts
A Canadian citizen who became a U.S. permanent resident maintained a Canadian RRSP and a locked-in retirement account after moving to the United States. The taxpayer did not make the election under…
PLR 1336009: IRS grants treaty-election relief for three Canadian RRSPs
A married couple owned three Canadian registered retirement savings plans and had not made the required election to defer U.S. taxation on income accruing in those accounts. Their Canadian and U.S.…
PLR 1336008: IRS grants more time for an extended consolidated NOL carryback election
A consolidated corporate group incurred a net operating loss and wanted to use the extended carryback period available under IRC § 172(b)(1)(H). The group missed the deadline to make the election…
PLR 1336007: IRS grants more time to elect consolidated return filing
A corporate parent and its subsidiary wanted to file a consolidated federal income tax return, but they missed the regulatory deadline to make the election. The parent said it reasonably relied on a…
PLR 1336005: IRS grants more time for an entity classification election
An entity formed in a state wanted to elect to be treated as an association taxable as a corporation for federal tax purposes. It was eligible to make the election under the entity-classification…
PLR 1336004: IRS grants more time to waive a consolidated NOL carryback
A consolidated corporate group wanted to elect to relinquish the entire carryback period for a consolidated net operating loss under Treas. Reg. § 1.1502-21(b)(3)(i), but the election was not timely…
PLR 1336002: IRS grants more time for an extended consolidated NOL carryback election
A consolidated corporate group incurred a net operating loss and wanted to use the extended carryback period available under IRC § 172(b)(1)(H). The group missed the deadline to make the election…
IRS allows a late election to restore value after an ownership change
The IRS granted a consolidated group an extension of time to file an election under the regulations governing § 382 limitations after an ownership change. A loss corporation had reduced its value…
IRS grants more time for an RRSP election under the U.S.-Canada treaty
The IRS granted a taxpayer an extension to make an election under Rev. Proc. 2002-23 to defer U.S. federal income tax on income accrued in a Canadian registered retirement savings plan. The taxpayer…
IRS grants more time for a consolidated NOL carryback election
The IRS granted a consolidated group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group had failed to make a valid election to carry back a…
IRS grants more time for a redacted § 48A election
The IRS granted a taxpayer an extension to make a redacted election associated with the qualifying advanced coal project credit under IRC § 48A. The taxpayer had relied on an independent law firm to…
IRS grants more time for a disregarded-entity classification election
The IRS granted a foreign eligible entity 120 days to make a late election to be treated as a disregarded entity for federal tax purposes. The entity had not timely filed Form 8832, Entity…
IRS grants more time for a disregarded-entity classification election
The IRS granted a foreign eligible entity 120 days to make a late election to be treated as a disregarded entity for federal tax purposes. The entity had not timely filed Form 8832, Entity…
IRS grants extra time to make an IC-DISC election
The IRS granted a domestic corporation an additional 90 days to file Form 4876-A and make an election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The…
Taxpayer receives more time to elect Canadian retirement-plan tax deferral
The IRS granted a Canadian taxpayer 60 days from the ruling date to elect under Rev. Proc. 2002-23 to defer U.S. federal income tax on income accrued in a Canadian registered retirement savings…
IRS grants more time to make a 2010 decedent basis election
The IRS granted an estate 120 additional days to file Form 8939 and make the section 1022 election for a decedent who died in 2010. The election allows an executor to use the special…
PLR 1333001: IRS grants more time to file a LIFO election form
The IRS granted a taxpayer 30 more days to file Form 970, the application to use the LIFO inventory method. The taxpayer had adopted the LIFO method but discovered after changing accounting firms…
PLR 1330029 grants late election relief for foreign entity classification
The IRS grants a foreign eligible entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had inadvertently failed to timely file Form 8832.…
PLR 1330028 grants late disregarded-entity election relief
The IRS grants a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity had failed to timely file Form 8832. The IRS concludes that…
PLR 1330015 grants more time to opt out of automatic GST exemption allocation
The IRS grants the executor of an estate 120 additional days to elect out of the generation-skipping transfer tax exemption's automatic allocation rules. The underlying transfers were cash and a…
PLR 1330014 grants more time to elect partnership classification
The IRS grants an entity 120 additional days to file an election to be treated as a partnership for federal tax purposes. The entity had intended to change its classification from an association…
PLR 1330013 grants more time to elect corporate classification
The IRS grants a foreign entity 120 additional days to file Form 8832 electing to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make that…
PLR 1330009 grants more time to elect disregarded-entity status
The IRS grants a foreign subsidiary 120 additional days to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The subsidiary had always intended to make that…
PLR 1330001 grants more time to waive a consolidated net operating loss carryback
The IRS grants a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group intended to make the election but…
PLR 1329014: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329013: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329012: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329011: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329010: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329009: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329008: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329007: IRS grants late-election relief for a worthless subsidiary stock loss
The IRS granted a consolidated group an extension of time to file regulatory elections related to a worthless-stock loss for a subsidiary. The parent had not claimed the deduction or filed the…
PLR 1329001: IRS grants extra time to make consolidated-return loss elections
The IRS granted a consolidated group an extension of time to file elections concerning the recognition of a loss on worthless subsidiary stock. The group represented that it had reasonably relied on…
PLR 1328028: IRS grants extra time to elect an extended NOL carryback
The IRS granted a consolidated group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group represented that it had reasonably relied on a…
PLR 1328021: IRS grants extra time to elect corporate classification for an LLC
The IRS granted a single-member LLC an extension of time to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC represented that it had always intended to…
PLR 1328019: IRS grants extra time for multiple QSub elections
The IRS granted a corporation 120 days to make elections treating several wholly owned subsidiaries as qualified subchapter S subsidiaries. The taxpayer had inadvertently filed separate S…
PLR 1328002: IRS grants extra time to make low-income housing elections
The IRS granted a taxpayer 120 days to make intended elections under IRC § 42(g)(1)(B) for a multiple-building low-income housing project. The taxpayer had made incorrect or untimely elections on…
PLR 1327005: IRS grants more time to file an IC-DISC election
The IRS granted a domestic corporation 60 more days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The corporation's…
PLR 1327004: IRS grants more time to file an IC-DISC election for a fishing business
The IRS granted a domestic corporation 60 more days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The corporation's…
PLR 1327001: IRS grants more time to file an IC-DISC election after the filing could not be located
The IRS granted a domestic corporation 60 more days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The taxpayer had…
PLR 1326010: Foreign entity receives more time to elect disregarded-entity status
The IRS granted a foreign entity more time to file an election to be treated as a disregarded entity for federal tax purposes. The entity was wholly owned by one taxpayer and intended to make the…
PLR 1325008: IRS grants more time to make a qualified subchapter S subsidiary election
An S corporation acquired all of the stock of another corporation but did not timely file Form 8869 to elect qualified subchapter S subsidiary status for the subsidiary. The IRS concluded that the…
PLR 1325004: IRS grants extra time to elect qualified real property indebtedness treatment
An individual received discharge-of-indebtedness income through a partnership after a lender forgave debt used to acquire an interest in real property. The taxpayer did not report the income or…
IRS grants extra time for a research-cost election
A consolidated corporate group missed the deadline to elect under IRC § 59(e) to amortize certain research and experimental expenditures over ten years. The taxpayer said its tax preparer did not…
PLR 1324014: IRS grants more time to elect a multi-building low-income housing project
A taxpayer asked the IRS for more time to identify all buildings in a low-income housing project as part of a single, multiple-building project for section 42 purposes. The taxpayer said the…
PLR 1324008: IRS grants extra time for a research-cost amortization election
The IRS granted a taxpayer 60 additional days to make an election under IRC § 59(e) to amortize certain research and experimental expenditures. The taxpayer missed the election because its tax…
PLR 1323011: IRS grants more time for an extended consolidated NOL carryback election
The IRS considered a consolidated corporate group that missed the deadline to elect an extended carryback period for a consolidated net operating loss. The group showed that it reasonably relied on…
PLR 1323010: IRS grants more time to elect consolidated-return treatment
The IRS considered a parent corporation and subsidiaries that missed the deadline to elect consolidated-return treatment after an acquisition. The taxpayers showed that they reasonably relied on…
PLR 1323009: IRS grants more time for an insurance company to make the §831(b) election
The IRS considered a property and casualty insurance company that wanted to elect the alternative tax under section 831(b). The company said it missed the election deadline after relying on a…
PLR 1323008: IRS grants a consolidated group more time to file section 1.1502-36 elections
The IRS considered a consolidated group that had not timely filed specified elections relating to reductions of subsidiary stock bases and tax attributes after a series of distributions and a later…
PLR 1322039: IRS grants an estate 120 more days to make the 2010 basis election
The IRS granted the personal representative of an estate 120 additional days to file Form 8939 and make the section 1022 election. The decedent died in 2010, and the representative had retained tax…
PLR 1322034: IRS grants a consolidated group more time to waive an NOL carryback
The IRS granted a consolidated corporate group 45 additional days to file an irrevocable election to relinquish the entire carryback period for a consolidated net operating loss. The parent had…
PLR 1322031: IRS grants more time for a trust severance and reverse QTIP election
The IRS granted an estate 120 additional days to divide a marital trust into GST-exempt and GST-non-exempt trusts and make a reverse QTIP election for the exempt trust. The estate had filed an…
PLR 1322022: IRS grants more time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification…
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.