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.
PLR 1322021: IRS grants more time for a foreign entity to elect partnership status
The IRS granted a foreign entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was eligible for that classification but had…
PLR 1322019: IRS grants more time for a 2010 estate to make a basis election
The IRS granted a decedent's personal representative an additional 120 days to file Form 8939 and make the section 1022 election. That election allows certain basis increases for property acquired…
PLR 1322002: IRS grants extra time for a consolidated-group election
The IRS granted a taxpayer an extension of time to file an election under Treas. Reg. § 1.1502-13(l)(3) for certain stock-elimination transactions in a consolidated group. The original common parent…
PLR 1321015: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321014: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321013: IRS grants more time for a foreign entity classification election
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended the election to be effective on…
PLR 1321006: IRS grants extra time to elect out of automatic GST exemption allocation
The IRS granted an estate 120 additional days to elect out of the automatic allocation of generation-skipping transfer tax exemption for several lifetime transfers. The transfers were made to two…
PLR 1321005: IRS grants extra time to elect out of automatic GST exemption allocation
The IRS granted a taxpayer 120 additional days to elect out of the automatic allocation of generation-skipping transfer tax exemption for several lifetime transfers. The transfers were made to two…
PLR 1321004: IRS grants late-election relief for foreign entity classification
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election…
PLR 1321003: IRS grants extra time for a 2010 estate basis election
The IRS granted the personal representative of a 2010 decedent’s estate 120 additional days to file Form 8939, make the § 1022 election, and allocate additional basis to eligible property. The…
PLR 1321002: IRS grants extra time to allocate GST exemption to a trust
The IRS granted a donor 120 additional days to allocate available generation-skipping transfer tax exemption to an irrevocable trust. The donor’s attorneys were expected to prepare and timely file a…
PLR 1321001: IRS grants two foreign entities more time to elect disregarded-entity status
Two foreign entities asked the IRS for more time to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. Their parent intended the elections to be effective on…
PLR 1320022: IRS grants more time to recharacterize Roth IRA conversions
An individual asked the IRS for more time to recharacterize two Roth IRA conversions as contributions to traditional IRAs. The individual relied on a tax attorney's advice and later learned that the…
PLR 1320016: IRS grants more time to elect corporate tax classification
The IRS considered a business entity's request for extra time to elect to be treated as an association taxable as a corporation. The entity had been formed in a state, defaulted to partnership…
PLR 1320015: IRS grants more time to elect out of additional depreciation
The IRS considered a corporation's request for extra time to elect not to claim 100-percent additional first-year depreciation for certain classes of property. The corporation had filed its tax…
PLR 1320013: IRS allows a late election concerning tax-exempt use property
The IRS considered a corporation's request to make a late election under § 168(h)(6)(F)(ii). The corporation was owned by a tax-exempt parent and held an interest in a partnership that owned…
PLR 1320011: IRS grants more time to elect QSub treatment
The IRS considered an S corporation's request for more time to elect to treat a wholly owned subsidiary as a qualified subchapter S subsidiary. The S corporation had purchased the subsidiary but…
PLR 1320005: IRS grants more time for a trust severance and reverse QTIP election
The IRS considered an estate's request to divide a marital trust into GST-exempt and GST-nonexempt trusts and make a reverse QTIP election after the original estate tax return omitted those actions.…
PLR 1320004: IRS approves a trust modification without adverse tax consequences
The IRS considered a proposed modification to an irrevocable trust that would give trustees discretion to distribute or accumulate income instead of requiring annual distributions. The trust had a…
PLR 1319008: Partnership granted more time to elect capitalization of carrying charges
The IRS granted a partnership an additional 30 days to make a section 266 election to capitalize interest, property taxes, and other carrying charges for two taxable years. The partnership had…
PLR 1319005: New parent granted more time to elect consolidated filing
The IRS granted a new parent corporation 60 days to make an election to file a consolidated federal income tax return for a short tax year. The election was missed because the parent reasonably…
PLR 1318007: IRS grants extra time to file Form 3115 for an accounting-method change
The IRS granted a taxpayer a 60-day extension to file an original Form 3115 with an amended consolidated return. The form was needed to request an accounting-method change for repair and maintenance…
PLR 1318002: IRS grants extra time to file Form 3115 after taxpayer relied on a tax professional
The IRS granted a taxpayer a 60-day extension to file the original Form 3115 needed to change its accounting method. The taxpayer had filed the form but failed to attach a copy to its consolidated…
PLR 1317008: IRS grants extra time to make section 338(g) elections
The IRS granted a purchaser 45 days to make section 338(g) elections for the acquisition of one target and the deemed acquisitions of two subsidiaries. The elections had been missed because the…
PLR 1317006: IRS grants extra time to file a LIFO election
The IRS granted a taxpayer 30 additional days to file Form 970, the form used to elect the LIFO inventory method. The taxpayer had received inventory during an internal restructuring but had not…
PLR 1317002: IRS grants extra time to elect the section 831(b) alternative tax
The IRS granted an insurance company 60 days to make a section 831(b) election for a specified tax year. The company had missed the deadline after its accounting firm failed to request an extension…
IRS grants more time to amend consent-dividend elections
The IRS granted a REIT an additional 45 days to amend consent-dividend elections after it mistakenly attributed all of the consent dividends to common stock instead of allocating some to…
IRS grants time for trust severance and reverse QTIP election
The IRS granted an estate 120 days to sever a marital trust into exempt and non-exempt trusts and make a reverse QTIP election for generation-skipping transfer tax purposes. The estate had timely…
IRS grants extra time to make a qualified real property debt election
The IRS granted an individual an additional 45 days to make an election to exclude cancellation-of-debt income from qualified real property business indebtedness and reduce the basis of depreciable…
IRS grants extra time to make a qualified real property debt election
The IRS granted an individual an additional 45 days to make an election to exclude cancellation-of-debt income from qualified real property business indebtedness and reduce the basis of depreciable…
IRS grants extra time to waive a life subgroup loss carryback
The IRS granted a parent company 60 days to file an election relinquishing the carryback period for a consolidated loss from operations of a life insurance subgroup. The election was not timely…
IRS grants extra time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled corporation 60 days to make an election under section 168(h)(6)(F)(ii). The election allows the corporation to be treated as not tax-exempt for purposes of…
IRS grants extra time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled corporation 60 days to make an election under section 168(h)(6)(F)(ii). The election allows the corporation to be treated as not tax-exempt for purposes of…
Taxpayer granted extra time to elect treatment of capital gains as investment income
An individual asked for more time to elect to treat net capital gains as investment income for purposes of the investment interest deduction. The election had been missed because the taxpayer's…
Extra time granted to opt out of automatic GST exemption allocation
Spouses asked for more time to elect out of the automatic allocation of generation-skipping transfer tax exemption to several trusts. Their accountant had not advised them that the election was…
Extra time granted to opt out of automatic GST exemption allocation
Spouses asked for more time to elect out of the automatic allocation of generation-skipping transfer tax exemption to several trusts. Their accountant had not advised them that the election was…
PLR 1315014: Taxpayers receive more time to allocate GST exemption
The IRS granted an extension of time for two taxpayers to allocate generation-skipping transfer tax exemption to transfers made to an irrevocable trust. An accountant prepared the taxpayers' gift…
PLR 1315013: Estate receives 120 more days to make the section 1022 election
The IRS granted an estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property acquired from a decedent who died in 2010. The…
PLR 1315011: Estate receives more time to make the section 1022 election
The IRS granted the co-trustees of an estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property acquired from a decedent who…
PLR 1315006: Taxpayer receives more time to allocate GST exemption to a trust transfer
The IRS granted a taxpayer an additional 120 days to allocate generation-skipping transfer tax exemption to a lifetime transfer of limited partnership interests to an irrevocable trust. The taxpayer…
PLR 1315005: Estate receives more time to allocate GST exemption to trust transfers
The IRS granted a 120-day extension to allocate a deceased spouse's available generation-skipping transfer tax exemption to transfers made to a trust over 21 years. The couple had hired an…
PLR 1315002: Consolidated group receives more time to make an extended NOL carryback election
The IRS granted a consolidated corporate group 60 additional days to make an election for an extended carryback period for a consolidated net operating loss. The group missed the election deadline…
PLR 1314039: Extension granted to correct a foreign entity classification election
A foreign single-owner entity intended to elect disregarded-entity status for federal tax purposes, but it mistakenly filed Form 8832 to be treated as an association taxable as a corporation. The…
PLR 1314037: Extension granted for a late disregarded-entity election
A foreign eligible entity failed to timely file Form 8832 to elect disregarded-entity status for federal tax purposes. The IRS found that the entity acted reasonably and in good faith and that…
PLR 1314033: IRS grants late election relief for a tax-exempt controlled entity
A corporation wholly owned by a tax-exempt parent was involved in a historic rehabilitation project. The corporation intended to elect under IRC § 168(h)(6)(F)(ii) not to be treated as a tax-exempt…
PLR 1314032: IRS grants extra time to elect out of automatic GST-exemption allocation
A donor transferred one-third interests in real property to each of three grandchildren. The donor's tax professional intended to request an extension for the donor's gift tax return but failed to…
PLR 1314030: IRS grants late entity-classification and S corporation election relief
An LLC intended to be treated as an S corporation effective on a specified date, but it did not timely file Forms 8832 and 2553. The IRS found that the taxpayer satisfied the standards for relief…
PLR 1314027: IRS grants late election relief for a Canadian retirement plan
A U.S. citizen living in Canada had an RRSP established before moving to the United States. The taxpayer filed U.S. returns but did not know about the election needed to defer U.S. tax on RRSP…
PLR 1314019: IRS grants extra time for a Canadian RRSP election
The IRS granted a U.S. resident 60 days to make an election under Rev. Proc. 2002-23 for a Canadian registered retirement savings plan. The taxpayer became a U.S. resident after establishing the…
PLR 1314018: IRS grants more time to allocate GST exemption to trust transfers
The IRS granted a donor 120 days to allocate available generation-skipping transfer tax exemption to six earlier transfers into irrevocable trusts. The donor’s accountant prepared the gift tax…
PLR 1314017: IRS extends time to file mental-disability evidence for a GST tax transition rule
The estate of a decedent asked for more time to file a qualified physician's certification or other evidence that the decedent was mentally disabled continuously from October 22, 1986, until death.…
PLR 1314016: IRS grants controlled foreign corporations more time to file Form 3115
A parent company asked for more time to file the original Form 3115 needed to change the amortization accounting method of seven controlled foreign corporations. The parent had timely filed a signed…
PLR 1314015: IRS grants an LLC more time to elect partnership classification
A limited liability company asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The LLC was eligible for partnership treatment but missed the…
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 1314011: IRS grants an estate more time to make a Section 1022 basis election
An estate asked for more time to file Form 8939, make the Section 1022 Election, and allocate basis increases to eligible property transferred from a decedent. The estate's accountant failed to…
PLR 1314009: IRS grants more time to waive additional first-year depreciation
A corporation asked for more time to elect not to claim additional first-year depreciation for certain classes of property placed in service during two taxable years. Its accounting firm had omitted…
PLR 1314007: IRS grants an estate more time to make a section 1022 election
The personal representatives of an estate asked for more time to file Form 8939 and make the section 1022 election for property transferred after the decedent's death. The estate's tax professional…
PLR 1314006: IRS restores S corporation status and permits a late QSub election
A corporation's S corporation election was ineffective because one shareholder was not eligible to own S corporation stock. The corporation transferred that shareholder's stock to eligible…
PLR 1313017: IRS grants more time for a taxable REIT subsidiary election
A REIT and its subsidiary asked for extra time to file Form 8875, the form used to elect to treat the subsidiary as a taxable REIT subsidiary. The entities said they intended the subsidiary to have…
PLR 1313011: 120-day extension granted for entity-classification election
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be classified as an association, treated as a corporation, for federal tax purposes. The company had missed 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.