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 1237006: IRS grants late IC-DISC election relief
The IRS granted a corporation 60 days to file Form 4876-A to elect IC-DISC status for its first taxable year. The corporation had filed the form one day late because of a clerical error and argued…
PLR 1237004: IRS grants late election relief for a Canadian RRSP
The IRS granted a taxpayer 60 days to make an election under Revenue Procedure 2002-23 concerning a Canadian Registered Retirement Savings Plan. The election allows the taxpayer to defer current…
PLR 1237003: IRS grants extra time to file a duplicate accounting-method application
The IRS granted a corporation an extension of time to file a signed duplicate copy of Form 3115, Application for Change in Accounting Method, with the IRS Ogden office. The corporation's accounting…
PLR 1237002: Married taxpayers receive more time to elect Canadian RRSP tax deferral
The IRS granted a married couple 60 days to elect treaty treatment that defers U.S. tax on income accrued in their Canadian registered retirement savings plans, or RRSPs. The couple had moved to the…
PLR 1236024: 120-day extension granted to make an entity classification election
A foreign eligible entity asked for more time to file Form 8832 and elect partnership classification for federal tax purposes. The entity had intended the election to be effective on a specified…
PLR 1236021: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236020: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236019: 120-day extension granted for an entity classification election
A foreign limited liability company asked for more time to file Form 8832 and elect a classification other than its default federal tax classification. The company had inadvertently missed the…
PLR 1236017: Late Section 198 election treated as perfected
A corporate taxpayer deducted qualified environmental remediation expenditures but its tax preparer omitted the words “Section 198 Election” from the required schedules for two tax years. The…
PLR 1236016: 120-day extension granted for disregarded-entity election
A foreign company intended to elect disregarded-entity treatment for federal tax purposes but did not timely file Form 8832. The company asked for an extension of time to make the election effective…
PLR 1236015: IRS grants extra time to make an extended NOL carryback election
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 missed the election deadline while relying on a…
PLR 1236013: IRS grants extra time to elect research-cost amortization
The IRS granted a taxpayer 60 days to make a late election to amortize certain research and experimental expenditures over ten years. The election applied to expenditures from three redacted taxable…
PLR 1236012: IRS grants time to make a depreciation election
The IRS granted an S corporation 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the required election statement from its…
PLR 1236011: IRS grants partnership time to make a depreciation election
The IRS granted a limited liability company treated as a partnership 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the…
PLR 1236010: IRS grants time to make a machinery depreciation election
The IRS granted an S corporation 60 days to make a late election not to claim additional first-year depreciation under IRC § 168(k). The taxpayer had omitted the required election statement from its…
PLR 1236002: IRS grants extra time for an estate's alternate valuation election
The IRS granted an estate additional time to make the alternate valuation election under section 2032. The estate's tax professionals had failed to advise the administratrix about the election, and…
PLR 1236001: IRS grants extra time for a foreign entity classification election
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 had inadvertently missed the…
PLR 1235030: IRS grants extra time to recharacterize Roth IRA conversions
The IRS granted a married couple up to 60 days to recharacterize two Roth IRA conversions as traditional IRA contributions. The couple had converted traditional IRAs in 2009, when their income…
Extension granted for a late foreign-currency election
A U.S. corporation requested more time to make a foreign-currency gain or loss election for a controlled foreign corporation. The election had been omitted from a consolidated return even though the…
Extension granted for consolidated NOL carryback election
A consolidated corporate group requested more time to elect an extended carryback period for a consolidated net operating loss. The group intended to make the election but failed to file a valid…
Extension granted for a late ratable allocation election
An affiliated group and a subsidiary asked for more time to make a ratable allocation election after the subsidiary left the consolidated group. The IRS concluded that the taxpayers acted reasonably…
Late Roth IRA recharacterization allowed
A married couple made a Roth IRA conversion even though their income was above the applicable 2008 limit. They asked for more time to recharacterize the failed conversion as a traditional IRA…
IRS grants extra 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 net operating loss carryback period. The group had failed to timely file the election after…
IRS denies section 9100 relief for a late NOL carryback election
The IRS denied a request for extra time to make an election to carry back a net operating loss three, four, or five years under section 172(b)(1)(H). The taxpayers’ return was filed late after…
IRS grants extra time for a rehabilitation credit pass-through election
The IRS granted a taxpayer 120 days to make a late election that would pass rehabilitation credits from a property owner to its tenant. The taxpayer had relied on an attorney and a certified public…
IRS grants extra time to allocate generation-skipping transfer tax exemption
The IRS granted a taxpayer 120 days to allocate generation-skipping transfer tax exemption to two transfers made to an irrevocable trust. The taxpayer's accounting firm had prepared and filed the…
IRS grants extra time to elect partnership classification
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had intended to make that classification effective…
IRS grants extra time to elect disregarded-entity treatment
The IRS granted a foreign single-member entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification to…
IRS grants extra time for an extended consolidated NOL carryback election
The IRS granted a consolidated group 60 days to make an election under section 172(b)(1)(H) to carry back a consolidated net operating loss for three, four, or five years instead of the usual…
IRS grants extra time for a tax-exempt controlled entity election
The IRS granted a tax-exempt controlled corporation 60 additional days to make an election under section 168(h)(6)(F)(ii). The election allowed the corporation not to be treated as a tax-exempt…
PLR 1233013: IRS grants more time to allocate generation-skipping transfer tax exemption
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer (GST) tax exemption to a transfer to an irrevocable trust. The taxpayer had relied on a qualified tax…
PLR 1233011: IRS limits the retroactive effect of a prior ruling's revocation
The IRS granted relief under IRC § 7805(b) so that the revocation of an earlier private letter ruling would apply prospectively rather than retroactively. The earlier ruling had improperly granted…
PLR 1233006: IRS grants more time for an extended net operating loss 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 intended to make the…
PLR 1233005: IRS grants more time to file a LIFO inventory method election
The IRS granted a taxpayer an extension of time to file Form 970, the application to use the last-in, first-out inventory method. The taxpayer had implemented the LIFO method but failed to file the…
PLR 1233003: IRS grants more time to elect qualified subchapter S subsidiary status
An S corporation acquired all of the stock of a subsidiary and intended to elect qualified subchapter S subsidiary status for the subsidiary. The election was not timely filed because of…
PLR 1232031: IRS grants late-election relief for partnership classification
A domestic limited liability company intended to be treated as a partnership but did not timely file Form 8832. The taxpayer represented that it had filed federal tax returns consistently with that…
PLR 1232028: IRS grants more time to allocate generation-skipping transfer tax exemption
The estate of a deceased taxpayer and the taxpayer's spouse had failed to allocate generation-skipping transfer tax exemption to an irrevocable trust. The failure occurred because their tax…
PLR 1232025: IRS grants more time to elect treaty deferral for Canadian retirement plans
Two married taxpayers maintained Canadian Registered Retirement Savings Plans after moving to the United States. They had not filed the required Forms 8891 or otherwise elected under Article…
PLR 1232019: IRS grants more time to divide a reverse-QTIP trust for GST tax purposes
After a decedent's estate made a reverse QTIP election and allocated generation-skipping transfer tax exemption to a trust, the trustees sought to divide that trust into two separate trusts. One…
PLR 1232017: IRS grants more time to restore value under the controlled-group loss rules
A parent corporation and certain subsidiaries were members of a controlled group when the parent underwent an ownership change. The group had failed to timely elect under the regulations to restore…
PLR 1232016: IRS grants more time to restore value under the controlled-group loss rules
A parent corporation and certain subsidiaries were members of a controlled group when the parent underwent an ownership change. The group had failed to timely elect under the regulations to restore…
PLR 1232013: IRS grants more time to file a LIFO inventory election
A taxpayer discovered that it had failed to file Form 970 when it first adopted the last-in, first-out (LIFO) inventory method under IRC § 472. The taxpayer had used the LIFO method in its reports…
PLR 1232012: IRS grants more time to file a LIFO election after a restructuring
A successor discovered that a taxpayer had failed to file Form 970 when an internal restructuring resulted in the incorporation of a division as the taxpayer. The taxpayer had adopted the LIFO…
PLR 1232010: IRS grants more time to elect disregarded-entity status
A foreign limited liability company had one owner and was intended to be treated as a disregarded entity for federal tax purposes. The owner failed to timely file Form 8832, Entity Classification…
IRS grants extra time to elect the 40-60 test for a residential rental bond project
The IRS granted a public issuer 45 additional days to amend Form 8038 and elect the 40-60 test for tax-exempt private activity bonds financing a residential rental project. The issuer had mistakenly…
IRS grants an estate more time to allocate GST exemption
The IRS granted an estate 120 additional days to allocate the decedent’s generation-skipping transfer tax exemption to a lifetime transfer to an irrevocable trust. The taxpayer’s tax professional…
IRS grants more time to opt out of bonus depreciation
The IRS granted a domestic partnership 60 days to make a late election not to claim 50-percent and 100-percent additional first-year depreciation for all qualifying property placed in service during…
PLR 1231009: IRS grants more time to elect corporate tax classification
A business entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The IRS concluded that the entity acted…
PLR 1231005: IRS grants more time to elect corporate classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to make the…
PLR 1231003: IRS grants more time to file the 2010 estate basis election
The personal representative of an estate asked for more time to file Form 8939 and make the election under IRC § 1022 for an individual who died in 2010. A qualified tax professional had been…
PLR 1231002: IRS grants more time to allocate GST exemption to a trust
An individual asked for more time to allocate generation-skipping transfer tax exemption to a trust after the allocation was omitted from the individual's gift tax return. The individual had…
PLR 1230029: IRS grants more time to recharacterize an ineligible Roth IRA conversion
A married couple asked the IRS for more time to recharacterize a traditional IRA conversion as a contribution to a traditional IRA after their income made them ineligible for the Roth IRA…
PLR 1230023: IRS grants more time to elect special-use valuation for farmland
The IRS granted an estate more time to elect special-use valuation for farmland included in a decedent's estate. The executor timely filed the estate tax return but omitted the election, and a…
PLR 1230018: IRS grants time to withdraw an excess nuclear decommissioning-fund contribution
The IRS granted a utility 120 days to withdraw an excess contribution and related earnings from a qualified nuclear decommissioning fund. The utility had calculated a special transfer using the…
PLR 1230012: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect a deferral of U.S. income tax on earnings in a Canadian Registered Retirement Savings Plan under the U.S.-Canada Income Tax Treaty and Rev. Proc. 2002-23.…
PLR 1230010: IRS grants more time for a foreign partnership election
The IRS granted a foreign eligible entity 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the form timely for its…
PLR 1230006: IRS grants late-election relief for a change in tax year
The IRS granted a taxpayer's request to treat a late Form 1128 as timely filed. The form requested a change in the taxpayer's accounting period from a year ending December 31 to a year ending…
PLR 1230005: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to elect an extended carryback period for a consolidated net operating loss. The group missed the deadline because it relied on a…
PLR 1230004: IRS grants more time for an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent intended to make the election but…
PLR 1230003: IRS grants more time to make an extended NOL carryback election
The IRS granted a consolidated group's request for more time to make an election for an extended carryback period for a consolidated net operating loss. The parent missed the deadline after relying…
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.