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 1306002: IRS grants extra time to elect out of automatic GST exemption allocation
A married couple transferred assets to a trust for their grandchildren and intended that the transfer would not use their generation-skipping transfer tax exemption. Their accountants prepared the…
PLR 1306001: IRS grants extra time for a consolidated NOL carryback election
A consolidated corporate group failed to timely make an election to carry back a consolidated net operating loss for an extended period under IRC § 172(b)(1)(H). The IRS found that the parent…
IRS denies late request to change a corporation's tax year
A corporation asked the IRS to treat its late Form 1128 as timely so it could change its federal tax year from one ending August 31 to one ending March 31. The corporation had missed the deadline…
PLR 1305010: IRS grants extra time to waive an NOL carryback period
A parent company asked for more time to file an election waiving the entire carryback period for a consolidated group's net operating loss. The election was late because the parent relied on a…
PLR 1305009: IRS treats a late Form 1128 as timely filed
A taxpayer filed Form 1128 late to change its federal tax year from a December 31 year-end to a March 31 year-end. The taxpayer requested relief under § 301.9100-3 shortly after the filing deadline.…
PLR 1305008: IRS denies late Form 1128 relief filed after 90 days
A taxpayer filed Form 1128 late to change its federal tax year from an August 31 year-end to a March 31 year-end. The taxpayer did not request relief under § 301.9100-3 until more than 90 days after…
PLR 1305005: IRS grants extra time for an extended NOL carryback election
A parent company asked for more time to elect an extended carryback period for a consolidated group’s net operating loss. The election was not filed on time because the parent relied on a qualified…
PLR 1305002: IRS grants extra time to make an IC-DISC election
A domestic corporation intended to be treated as an interest charge domestic international sales corporation, or IC-DISC, for its first taxable year. Its Form 4876-A election was filed late after…
PLR 1304001: IRS grants late-election relief for an IC-DISC
A domestic corporation asked the IRS for permission to make a late election to be treated as an interest charge domestic international sales corporation, or IC-DISC. Its advisers completed most of…
PLR 1303007: Taxpayer receives more time to elect out of additional depreciation
A taxpayer that rehabilitated and operated an affordable apartment community intended to elect out of the additional first-year depreciation deduction for its qualified property. Its tax preparer…
PLR 1303006: Estates receive more time to allocate GST tax exemptions to trust transfers
The estates of a husband and wife asked for more time to allocate their generation-skipping transfer tax exemptions to transfers of company stock made to three irrevocable trusts. The IRS concluded…
PLR 1303004: Estate receives more time to make a section 1022 election
An estate representative asked for more time to file Form 8939, make the section 1022 election, and allocate basis increases to property transferred after the decedent's death. The representative…
PLR 1303002: IRS grants more time to file accounting-method change forms
An affiliated group of corporations asked for more time to file Form 3115 and make accounting-method changes for accrual accounting and deferred reporting of advance payments. The group had filed…
PLR 1303001: IRS grants late election relief for a tax-exempt controlled entity
A tax-exempt controlled corporation asked for more time to make an election under section 168(h)(6)(F)(ii) to be treated as a taxable entity for depreciation rules. The corporation had intended to…
PLR 1302014: IRS grants more time to elect the low-income housing credit set-aside
The IRS granted a taxpayer more time to make the election under IRC § 42(g)(1)(B) for a low-income housing project. The taxpayer placed the project in service but inadvertently failed to make the…
PLR 1302012: IRS grants late partnership classification election relief
The IRS granted a foreign eligible entity more time to elect partnership classification for federal tax purposes. The entity had failed to timely file Form 8832 for the intended effective date. The…
PLR 1302003: IRS grants more time to allocate generation-skipping transfer tax exemption
A donor asked the IRS for more time to allocate generation-skipping transfer tax exemption to gifts placed in three irrevocable trusts. The donor's accountant prepared and timely filed the gift tax…
PLR 1302002: IRS grants more time to allocate GST exemption to trust gifts
The executors of an estate asked for more time to allocate generation-skipping transfer tax exemption to gifts made to an irrevocable trust over several years. The donor's tax professionals either…
PLR 1302001: IRS grants more time to allocate GST exemption to family trusts
A married couple asked for more time to allocate generation-skipping transfer tax exemption to gifts made to two family trusts. The couple's attorney did not tell them that the allocations were…
IRS grants more time to recharacterize Roth IRA conversions
A married couple asked for extra time to recharacterize Roth IRA conversions back to traditional IRAs after receiving poor financial and tax advice. The IRS found that the taxpayers reasonably…
PLR 1301009: IRS grants extra time to elect an extended NOL carryback
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The group missed the filing deadline after relying on a qualified tax…
PLR 1301006: IRS grants extra time for a disregarded-entity election
A business entity asked for more time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended to make the election effective on a specified…
PLR 1301005: IRS grants extra time for a disregarded-entity election
A business entity asked for more time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended to make the election effective on a specified…
PLR 1252009: IRS granted late-election relief for REIT and taxable REIT subsidiary elections
The IRS granted a real estate investment trust an extension of time to elect REIT status for a taxable year. It also allowed the REIT and its subsidiary to make a late election treating the…
PLR 1252006: IRS granted late-election relief to reattribute a subsidiary's tax attributes
The IRS granted a consolidated group an extension of time to make an election reattributing a subsidiary's net operating loss carryover to the parent. The election followed a stock sale that…
PLR 1252004: IRS granted late GST trust election relief
The IRS granted a taxpayer 120 days to make a generation-skipping transfer tax election treating an irrevocable trust as a GST trust. The taxpayer had reported prior gifts but failed to make the…
PLR 1252003: IRS granted late GST trust election relief
The IRS granted a taxpayer 120 days to make a generation-skipping transfer tax election treating an irrevocable trust as a GST trust. The taxpayer had reported prior gifts but failed to make the…
PLR 1251011: IRS grants extra time to elect corporate classification
The IRS granted an eligible business entity an additional 120 days to file Form 8832 and elect to be classified as an association taxable as a corporation. The entity's default federal tax…
PLR 1251009: IRS permits revocation of an investment-income election after a software error
The IRS granted taxpayers 60 days to revoke an election that treated qualified dividends and capital gains as investment income. The taxpayers had made the election on Form 4952, but computerized…
PLR 1251008: IRS grants extra time to file a consolidated return election
The IRS granted a corporate parent and members of its affiliated group 45 days to make a consolidated return election for a short taxable year. The group missed the regulatory deadline after the…
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 1251001: IRS grants extra time to allocate generation-skipping transfer tax exemption
The IRS granted a settlor 120 days to allocate available generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The settlor had provided the relevant documents to an…
PLR 1250018: IRS grants extra time to make a qualified subchapter S subsidiary election
The IRS granted a corporation an additional 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary, or QSub. The corporation had intended the election to take…
PLR 1250016: IRS grants extra time 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 disregarded as an entity separate from its owner for federal tax purposes. The entity was…
PLR 1250015: IRS grants extra time to make a success-based fee safe harbor election
The IRS granted a taxpayer 45 additional days to attach the required statement for an election under Revenue Procedure 2011-29. The taxpayer used the safe harbor for allocating success-based fees…
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 1250002: IRS grants extra time to elect an extended NOL carryback
The IRS granted a consolidated group 60 days to file an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline while relying on a…
PLR 1249010: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated corporate group an extension of time to make an election for an extended carryback period for a consolidated net operating loss. The election had not been timely…
PLR 1249008: IRS grants more time for a partnership classification election
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had failed to timely file Form 8832, even though it was…
PLR 1249007: IRS extends time to file a consolidated return election
The IRS granted a new parent company more time to elect consolidated return treatment for a taxable year after a corporate acquisition and merger changed the affiliated group. The group had intended…
PLR 1249004: IRS grants more time for an extended net operating loss carryback election
The IRS granted a consolidated group 60 more days to make an election for an extended carryback period for a consolidated net operating loss. The group missed the deadline for the election, which…
PLR 1249003: IRS grants more time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled entity 30 more days to elect to be treated as a taxable entity for purposes of the depreciation rules. The entity was a co-general partner in a low-income…
PLR 1248015: IRS grants more time for an oil and gas intangible drilling cost election
The IRS granted an oil and gas joint venture 60 more days to elect to deduct intangible drilling costs. The partnership had not timely made the section 263(c) election for a taxable year, and it…
PLR 1248014: IRS grants more time for an oil and gas intangible drilling cost election
The IRS granted an oil and gas joint venture 60 more days to elect to deduct intangible drilling costs. The partnership had not timely made the section 263(c) election for a taxable year, and it…
PLR 1248012: IRS grants more time for CNOL carryback elections
The IRS granted a consolidated group more time to revoke an election waiving a net operating loss carryback and to elect an extended carryback period. The group missed the deadline after relying on…
PLR 1248005: IRS grants more time for a foreign entity classification election
The IRS granted a foreign entity 120 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification but failed to…
PLR 1248004: IRS grants more time for a depreciation election
The IRS granted a utility company 60 more days to make an election for 100-percent additional first-year depreciation on certain components of a larger self-constructed property. The company had…
PLR 1248003: IRS grants more time to file an accounting method change form
The IRS granted a taxpayer 30 more days to file the original Form 3115 for an accounting method change involving bonus expenses. The taxpayer's advisor had filed a copy with the IRS but…
PLR 1247024: IRS grants more time for a qualified separate lines of business election
The IRS granted a diversified holding company six more months to file Form 5310-A and make a notice election for qualified separate lines of business. The company had relied on an employee-benefits…
PLR 1247007: IRS grants late-election relief for an S corporation and its QSubs
The IRS granted a corporation 120 days to file a late S corporation election and qualified subchapter S subsidiary elections. The corporation had converted from a limited liability company and…
PLR 1247006: IRS grants extra time for an LLC to elect corporate tax classification
The IRS granted a limited liability company 120 additional days to file an election to be treated as an association taxable as a corporation for federal tax purposes. The entity was eligible to make…
PLR 1247005: IRS grants more time to elect an extended net operating loss carryback
The IRS granted a consolidated group 60 additional days to make an election extending the carryback period for a consolidated net operating loss. The group had failed to timely file the election…
PLR 1246026: IRS grants more time for a partnership classification election
The IRS granted an entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes, effective on the date it revoked its S corporation election. The entity had…
PLR 1246025: IRS grants more time to request a revised nuclear decommissioning schedule
The IRS granted a nuclear-power taxpayer 120 days to request a revised schedule of ruling amounts for a qualified nuclear decommissioning fund under IRC § 468A. The taxpayer had received an NRC…
PLR 1246024: IRS grants more time to request a revised nuclear decommissioning schedule
The IRS granted a nuclear-power taxpayer 120 days to request a revised schedule of ruling amounts for a qualified nuclear decommissioning fund under IRC § 468A. The taxpayer had received an NRC…
PLR 1246023: IRS grants more time to request a revised nuclear decommissioning schedule
The IRS granted a nuclear-power taxpayer 120 days to request a revised schedule of ruling amounts for a qualified nuclear decommissioning fund under IRC § 468A. The taxpayer had received an NRC…
PLR 1246022: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted the executrices of an estate 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in…
PLR 1246021: IRS grants more time for a section 338(g) election
The IRS granted a purchaser 45 days to file a late IRC § 338(g) election for the stock of four controlled foreign corporations. The purchaser acquired the stock through disregarded entities but…
PLR 1246020: IRS grants more time for QTIP severance and reverse election
The IRS granted an estate 120 days to sever a QTIP trust into a GST-exempt QTIP trust and a GST-nonexempt QTIP trust and to make a reverse QTIP election for the exempt trust. The original decedent's…
PLR 1246018: IRS grants more time for a 2010 decedent's section 1022 election
The IRS granted an executor 120 days to file Form 8939, make the IRC § 1022 election, and allocate additional basis to eligible property transferred from a decedent who died in 2010. The executor…
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.