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 1313010: 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…
PLR 1313009: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313008: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313007: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313006: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313005: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313004: 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 for federal tax purposes. The company had missed the deadline for making the…
PLR 1313003: 120-day extension granted to allocate GST exemption to trusts
The IRS granted an estate 120 days to allocate the grantor's generation-skipping transfer tax exemption to two irrevocable trusts. The grantor's law firm had failed to make the required allocations…
PLR 1312029: IRS grants an estate more time to make the section 1022 election
The IRS granted the executors of an estate 120 additional days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The decedent died in 2010, and…
PLR 1312026: IRS treats a late accounting-period change request as timely
The IRS granted a taxpayer relief for a late Form 1128 requesting a change in its annual accounting period. The taxpayer sought to change its year end from February to April and filed the form after…
PLR 1312025: IRS grants more time to elect an extended NOL carryback
The IRS granted a consolidated corporate group 60 additional days to elect an extended carryback period for a consolidated net operating loss. The group intended to carry the loss back under section…
PLR 1312024: IRS approves elective stock-compensation cost-sharing methods
The IRS granted a multinational taxpayer prospective consent to use an elective method for measuring and timing employee stock options, restricted shares, and restricted share units included as…
PLR 1312021: IRS grants more time to decline bonus depreciation
The IRS granted a corporation 60 days to make a late election not to deduct additional first-year depreciation under section 168(k)(5). The corporation had claimed 100-percent bonus depreciation but…
PLR 1312019: IRS grants more time to waive a consolidated group's loss carryback
The IRS granted a successor corporation 45 days to make a late election for a consolidated group to waive the entire carryback period for a consolidated net operating loss. The taxpayer had failed…
PLR 1312018: IRS grants more time to elect out of automatic GST exemption allocation
The IRS granted a taxpayer 120 days to elect out of the automatic allocation of generation-skipping transfer tax exemption to transfers made to a trust. The taxpayer's gift tax return did not…
PLR 1312015: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312014: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312013: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312012: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312011: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312010: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312009: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312008: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312007: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312006: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312005: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312004: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312003: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312002: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1312001: IRS grants more time to classify an LLC as a corporation
The IRS granted a limited liability company 120 days to file Form 8832 and elect to be treated as an association, meaning a corporation, for federal tax purposes. The LLC had missed the deadline for…
PLR 1311020: IRS allows late filing of a Form 8716 tax-year election
The IRS granted a taxpayer relief for a late-filed Form 8716, which elects a tax year other than a required tax year. The taxpayer had hired a qualified tax professional, but the form was not filed…
PLR 1311019: IRS allows late filing of a Form 8716 tax-year election
The IRS granted a taxpayer relief for a late-filed Form 8716, which elects a tax year other than a required tax year. The taxpayer had hired a qualified tax professional, but the form was not filed…
PLR 1311017: IRS grants late-election relief for LLC classification and S corporation status
The IRS granted a limited liability company additional time to elect classification as an association taxable as a corporation and to file an S corporation election. The company had failed to timely…
PLR 1311016: IRS grants late-election relief under section 754
The IRS granted a partnership an additional 120 days to make a late election under IRC section 754. The partnership had failed to make the election after interests were transferred because its tax…
PLR 1311013: IRS grants extra time for a foreign entity classification election
The IRS granted a parent company 120 days to file Form 8832 for a wholly owned foreign entity to be treated as disregarded for federal tax purposes. The entity had failed to make the election on…
PLR 1311012: IRS grants extra time to attach an accounting method change form
The IRS granted a taxpayer 30 days to attach an original Form 3115 to an amended federal income tax return for a subsidiary's accounting method change involving tort liabilities. The taxpayer's…
PLR 1311009: IRS grants late REIT and taxable REIT subsidiary elections
The IRS treated a timberland investment trust's late election to be taxed as a real estate investment trust as timely made for one tax year. It also granted the trust and its subsidiary extra time…
PLR 1310025: Consolidated group granted extra time to elect an extended NOL carryback
The IRS granted a consolidated group 60 days to make an election for an extended carryback period for a consolidated net operating loss. The election was missed because the group reasonably relied…
PLR 1310024: Consolidated group granted extra time for an extended 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 missed the election deadline after relying on a…
PLR 1310022: Corporation granted extra time to elect QSubs
The IRS granted an S corporation 120 days to file elections treating two wholly owned subsidiaries as qualified subchapter S subsidiaries. The elections were missed through inadvertence, although…
PLR 1310018: Taxpayer receives more time to file an IC-DISC election
The IRS considered a domestic corporation's request for more time to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The…
PLR 1310015: Parent receives more time to file a § 337(d) loss statement
The IRS considered a parent company's request for more time to file a statement needed to elect relief under Treas. Reg. § 1.337(d)-2(c) for a loss on the sale of subsidiary stock. The parent said…
PLR 1310014: Taxpayers receive more time to make pollution-control and bonus-depreciation elections
The IRS considered a group of affiliated energy companies that had claimed certain deductions but failed to attach the required election statements to a timely filed consolidated return. It granted…
PLR 1310013: Business trust receives more time to elect corporate tax classification
The IRS considered a business trust that had failed to timely file Form 8832 to elect treatment as a corporation for federal tax purposes. The IRS found that the requirements for late-election…
PLR 1310012: Donors receive more time to allocate GST tax exemption to a trust
The IRS considered donors who had made a lifetime transfer to a trust but whose gift tax returns did not allocate their generation-skipping transfer tax exemption to that transfer. The failure was…
PLR 1310011: Donors receive more time to allocate GST tax exemption to a trust
The IRS considered donors who had made a lifetime transfer to a trust but whose gift tax returns did not allocate their generation-skipping transfer tax exemption to that transfer. The failure was…
PLR 1310007: Estate receives more time to make the Section 1022 election
The IRS considered an estate whose decedent died in 2010 and whose executor missed the deadline to file Form 8939. Form 8939 was needed to make the Section 1022 Election and allocate basis increases…
PLR 1309002: Estate received extra time to make the section 1022 election
The IRS considered an estate representative's request for more time to file Form 8939 and make the section 1022 election for property acquired from a decedent who died in 2010. It concluded that the…
PLR 1309001: Couple received extra time for Canadian pension elections
The IRS considered a married couple's request for more time to elect the treatment provided by Revenue Procedure 2002-23 for Canadian registered pension and retirement savings accounts. It found…
PLR 1308015: IRS grants extra time for a 2010 estate's basis election
The IRS granted a personal representative an extension of time to file Form 8939 for an estate whose decedent died in 2010. The form was needed to make the section 1022 election and allocate basis…
PLR 1308014: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1308013: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1308012: IRS grants extra time for a foreign entity's Form 8832 election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had been indirectly…
PLR 1308007: IRS grants extra time for a repair-allowance election
The IRS granted a taxpayer 60 days to make a repair-allowance election for expenditures associated with property placed in service before 1981. The taxpayer had claimed the repair allowance on…
PLR 1308006: IRS grants extra time for Canadian RRSP treaty elections
The IRS granted a U.S. resident 60 days to make an election under Rev. Proc. 2002-23 to defer U.S. federal income tax on income accrued in three Canadian Registered Retirement Savings Plans. The…
PLR 1308003: IRS grants more time for a Canadian RRSP tax election
The IRS granted a taxpayer and spouse an extension of time to make an election concerning U.S. taxation of income accrued in a Canadian registered retirement savings plan. The taxpayers had relied…
PLR 1307004: IRS grants more time to elect out of automatic GST exemption allocation
A married couple created an irrevocable trust for grandchildren and made a transfer to it. Their tax preparers filed the gift tax returns but failed to make the election that would prevent automatic…
PLR 1307003: IRS grants more time for a treaty election on Canadian RRSP earnings
A taxpayer who moved from Canada to the United States had two Canadian Registered Retirement Savings Plans. The taxpayer’s preparer did not advise the taxpayer to make the treaty election needed to…
PLR 1306020: IRS grants extra time to make a QSub election
The IRS granted an S corporation an extension of time to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The corporation had filed Form 2553 instead of Form 8869…
PLR 1306011: IRS grants more time for a 2010 estate's Section 1022 election
The trustee of an estate for a person who died in 2010 asked for more time to file Form 8939, make the Section 1022 Election, and allocate basis increases to eligible property. The request explained…
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.