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 1246016: IRS grants relief for a late disregarded-entity election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity had…
PLR 1246015: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246014: IRS grants more time for a foreign entity's disregarded-entity election
The IRS granted a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested date. The entity was eligible to make…
PLR 1246006: IRS grants relief for three late partnership elections
The IRS granted three foreign entities 120 days to file Form 8832 and elect partnership classification for federal tax purposes, effective on their intended dates. Each entity had failed to timely…
PLR 1246003: IRS allows an estate charitable deduction for distributed S corporation receivables
The IRS ruled that an estate could claim a charitable deduction under section 642(c) for receivables distributed to it by an S corporation and then paid to, or permanently set aside for, a…
PLR 1245016: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's personal…
PLR 1245015: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis increases to eligible property. The estate's executrix had…
PLR 1245013: IRS grants a trust more time to make a section 1022 election
The IRS granted the personal representatives of a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The…
PLR 1245012: IRS grants an estate more time to make a section 1022 election
The IRS granted a deceased person's estate an additional 120 days to file Form 8939, make the section 1022 election, and allocate basis to eligible property. The estate's personal representative…
PLR 1245009: IRS grants extra time to make an extended CNOL 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 not timely filed the election because it…
PLR 1245008: IRS grants extra time to make a trust distribution election
The IRS granted a trust 120 additional days to make a section 663(b) election. The trust had distributed an amount during the first 65 days of a tax year and intended the distribution to be treated…
PLR 1245005: IRS grants extra time to amend a 2010 estate basis allocation
The IRS granted a decedent's personal representative 120 additional days to amend Form 8939 for a 2010 estate. The timely filed form had omitted basis allocations for closely held business…
PLR 1244013: IRS grants extra time for a late Canadian RRSP election
Taxpayers who moved from Canada to the United States had Canadian registered retirement savings plan accounts. Their tax preparers did not tell them to make the election needed to defer U.S. tax on…
PLR 1244011: IRS grants more time to elect disregarded-entity treatment
A domestic corporation formed a foreign entity and intended to elect disregarded-entity treatment for it, but did not timely file Form 8832. The IRS concluded that the requirements for late-election…
PLR 1244009: IRS grants a REIT more time to declare a dividend for a prior-year election
A real estate investment trust intended to declare a dividend by the extended due date for its prior-year federal income tax return. Its tax department's new personnel did not advise it of the…
PLR 1244003: IRS grants more time for a PFIC mark-to-market election
A regulated investment company failed to identify two foreign corporations as passive foreign investment companies and did not make the IRC § 1296 mark-to-market elections for the prior tax year.…
PLR 1244001: IRS grants more time for a disregarded-entity election
A foreign eligible entity failed to timely file Form 8832 to elect classification as a disregarded entity for federal tax purposes, effective from its formation date. The IRS granted the entity 120…
PLR 1243012: Estate receives more time to complete a QDOT rollover and related filings
The IRS ruled for an estate whose surviving spouse was not a United States citizen and whose estate tax return made a qualified domestic trust (QDOT) election for a retirement account. The estate…
PLR 1243011: IRS denies late election for a low-income housing credit project
The IRS denied a taxpayer's request for more time to elect the month used to determine the applicable percentage for a low-income housing credit project financed with tax-exempt bonds. The taxpayer…
PLR 1243010: Trustee receives more time to make a 2010 basis election
The IRS granted a trustee 120 days to file Form 8939 and make the Section 1022 Election for property acquired from a decedent who died in 2010. The decedent's assets were held in a revocable trust,…
PLR 1243008: IRS extends time to elect QSub treatment for three subsidiaries
The IRS granted an S corporation 120 days to file Forms 8869 and elect to treat three wholly owned subsidiaries as qualified subchapter S subsidiaries. The parent had intended to make the elections…
PLR 1243007: IRS extends time to elect QSub treatment for a subsidiary
The IRS granted an S corporation 120 days to file Form 8869 and elect to treat a wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the QSub election but…
PLR 1243005: IRS grants an LLC more time to elect corporate tax treatment
The IRS granted a business entity an extension of time to elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had converted from a corporation to a…
PLR 1243004: Estate gets relief for QTIP and GST elections and trust divisions
The IRS granted an estate 120 more days to make a QTIP election, divide a trust into exempt and non-exempt trusts, make a reverse QTIP election, and allocate the decedent's available GST exemption.…
PLR 1242018: IRS grants more time to recharacterize invalid Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize Roth IRA conversions that were not permitted because their modified adjusted gross income exceeded the applicable limit. The couple…
PLR 1242010: IRS grants more time for a consolidated 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 group had intended to make the…
PLR 1242008: IRS grants a 60-day extension for a consolidated NOL election
The IRS granted a consolidated corporate group 60 days from the ruling date to make an election for an extended carryback period for a consolidated net operating loss. The group did not file a valid…
PLR 1242006: IRS grants 120 days to make a QSub election
The IRS granted a parent corporation 120 days to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the subsidiary's stock, made an S…
PLR 1242005: IRS grants 120 days to elect out of automatic GST allocation
The IRS granted trustees 120 days to elect out of the automatic allocation of generation-skipping transfer tax exemption for five lifetime transfers to trusts benefiting the donor's grandchildren.…
PLR 1242004: IRS extends time for elections covering Canadian retirement plans
The IRS granted taxpayers 60 days to make elections under Rev. Proc. 2002-23 concerning Canadian registered retirement savings plans and registered pension plans. The taxpayers had moved from Canada…
IRS grants more time to sever a QTIP trust, make a reverse QTIP election, and allocate GST exemption
The IRS granted an estate additional time to divide a marital trust into exempt and non-exempt portions, make a reverse qualified terminable interest property (QTIP) election, and allocate the…
IRS grants extra time to file an IC-DISC election
The IRS granted a domestic corporation 60 additional days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation (IC-DISC). The corporation…
PLR 1240011: IRS grants more time to elect current deduction of drilling costs
Married taxpayers who invested in an oil and gas joint venture missed the deadline to elect current deductions for intangible drilling and development costs. Their first tax preparer did not know…
PLR 1240010: IRS extends time to allocate GST tax exemption to a trust
An estate and a surviving spouse asked for more time to allocate their generation-skipping transfer tax exemptions to transfers made to an irrevocable trust. An accountant had failed to allocate the…
PLR 1240008: IRS grants more time to make a section 754 election
A partnership asked for an extension of time to make a section 754 election after filing its tax return without the election. The election can adjust the basis of partnership property after certain…
PLR 1240004: IRS grants spouses more time to allocate GST exemption after gift splitting
Spouses elected to split a gift made to a trust, but their timely gift tax returns did not allocate generation-skipping transfer tax exemption to part of the transfer. The IRS concluded that they…
PLR 1240003: IRS grants spouses more time to allocate GST exemption after gift splitting
Spouses elected to split a gift made to a trust, but their timely gift tax returns did not allocate generation-skipping transfer tax exemption to part of the transfer. The IRS concluded that they…
PLR 1240002: IRS grants extra time to elect the alternative depreciation system
A limited partnership that operated an affordable housing community used the general depreciation system for property placed in service during two tax years, even though its partnership agreement…
PLR 1239015: IRS denies late recharacterization after Roth IRA funds left the accounts
A married couple converted traditional IRA funds to Roth IRAs in 2009 even though their modified adjusted gross income exceeded the applicable conversion limit. They did not learn of the problem…
PLR 1239012: IRS grants a nonprofit more time to revoke its lobbying election
An exempt public charity asked for more time to retroactively revoke its IRC § 501(h) lobbying election after becoming the sole member of an affiliated group. The organization said it had relied on…
PLR 1239005: IRS grants more time to elect treaty deferral for Canadian RRSP earnings
Two taxpayers who moved from Canada to the United States maintained Canadian registered retirement savings plans and did not timely elect to defer U.S. income taxation on the plans' accrued earnings…
PLR 1239004: IRS denies late trader mark-to-market election
A liquidated subsidiary asked the IRS to treat its use of mark-to-market accounting as substantial compliance with the IRC § 475(f) trader election requirements. In the alternative, it requested…
PLR 1238024: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238023: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238022: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238021: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238020: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238019: IRS grants extra time to elect qualified subchapter S subsidiary treatment
The IRS granted an S corporation an additional 120 days to make a late election to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had acquired all of the…
PLR 1238016: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a personal representative 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases…
PLR 1238012: IRS grants extra time for a 2010 decedent's basis election
The IRS granted the executors of an estate 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis…
PLR 1238011: IRS grants extra time for a 2010 decedent's basis election
The IRS granted a trustee 120 additional days to file Form 8939 and make the Section 1022 Election for an estate whose decedent died in 2010. The election would allow basis increases to be allocated…
PLR 1238009: IRS grants extra time for a taxable REIT subsidiary election
The IRS granted a company and its subsidiary 60 days to file a corrected Form 8875 and make an election to treat the subsidiary as a taxable REIT subsidiary, effective as of the requested date. The…
PLR 1238005: IRS grants extra time for a Canadian RRSP treaty election
The taxpayer, a Canadian citizen living permanently in the United States, held a Canadian Registered Retirement Savings Plan. The taxpayer and spouse had not made the election required to defer U.S.…
PLR 1238003: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238002: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1238001: IRS grants extra time to make a partnership basis election
The partnership intended to make a section 754 election with a timely filed return but inadvertently omitted the election. The partnership represented that it had filed later returns consistently…
PLR 1237015: IRS grants late QSub election relief
The IRS granted a corporation 120 days to make late elections treating four wholly owned subsidiaries as qualified subchapter S subsidiaries. The corporation had acquired the subsidiaries, failed to…
PLR 1237014: IRS grants late QSub election relief
The IRS granted a parent S corporation 120 days to make a late election treating its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had intended to make the election,…
PLR 1237011: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days from the ruling date to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer…
PLR 1237010: IRS grants late extended carryback election relief
The IRS granted a consolidated group 60 days to file a late election for an extended carryback period for a consolidated net operating loss. The group had intended to make the election under section…
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.