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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Partnership receives 120 days to make late Section 754 election
A limited liability company taxed as a partnership timely filed its return for a year in which partnership interests were transferred. It inadvertently omitted the Section 754 election that would…
Partnership receives conditional late Section 754 election relief
A limited partnership intended to make a Section 754 election but inadvertently omitted it from its timely filed return. It represented that it acted reasonably and in good faith and that relief…
Corporation receives 60 days for late success-fee safe-harbor election
A corporation incurred success-based transaction fees when its parent was acquired and the corporation moved into the acquirer's consolidated group. Its tax adviser prepared two short-period…
Utility deducts shared environmental mitigation payment
A utility paid its agreed share of another entity's cost to acquire water used solely to mitigate groundwater drawdown caused by a jointly developed generating facility. The IRS found the payment…
IRS denies exemption to gated RV tailgating park
A member-owned recreational-vehicle park used primarily for tailgating sought exemption as a social-welfare organization under Section 501(c)(4). Members paid assessments to maintain fenced common…
IRS approves pension plan substitute mortality tables
A single-employer defined benefit pension plan asked to use plan-specific substitute mortality tables for its funding calculations under Section 430. The IRS approved substitute tables for male and…
Partnership receives retroactive QEF election for PFIC stock
A domestic partnership received stock in a foreign corporation that was a passive foreign investment company, or PFIC. Two successive tax professionals were unaware of the corporation's PFIC status…
IRS accepts late taxable REIT subsidiary election
A real estate investment trust and an indirectly owned subsidiary intended the subsidiary to be a taxable REIT subsidiary from its formation date. They missed the Form 8875 deadline because the…
Foreign entity receives late partnership-classification election
A foreign limited liability company formed as a joint venture intended to be treated as a foreign partnership for U.S. tax purposes. Because both members had limited liability, the default…
Merged corporation receives late success-fee safe-harbor election
A corporation merged into a related company and needed to file a final short-period return. It intended to extend that return but failed to file Form 7004 before the deadline, so the return could no…
S corporation receives late QSub election relief
An S corporation acquired all the stock of a domestic subsidiary and intended to treat it as a qualified subchapter S subsidiary from the acquisition date. It inadvertently failed to file Form 8869…
Individual receives retroactive QEF election for family PFIC
An individual owned stock in a foreign family corporation that was a passive foreign investment company, or PFIC. Two successive tax professionals were unaware of the corporation's PFIC status and…
Five-year regulated restructuring follows one reorganization plan
A multinational corporate group planned to move a regulated foreign business and its branches into another foreign affiliate. The steps included ownership contributions, establishing and authorizing…
IRS approves grants to silent-film accompanists
A private foundation proposed grants to qualified musicians who would provide live accompaniment for public presentations of restored silent films. A committee of at least three people would select…
IRS approves charitable-leadership fellowship procedures
A private foundation proposed fellowships for promising leaders and innovators to pursue specific charitable objectives, with an initial focus on historically disenfranchised communities. Applicants…
IRS approves scholarship and individual-achievement grants
A private foundation proposed two types of grants supporting a cultural shift toward equality, partnership, and a caring society. Section 4945(g)(1) scholarships would help financially needy…
IRS approves international civic-leadership fellowships
A private foundation supported a year-long fellowship placing recent college graduates with mission-oriented organizations in three countries. Fellows would work full time, receive stipends, attend…
IRS approves three scientific grant programs
A private foundation proposed three grant programs supporting research and education in two scientific fields. One program would fund student research projects based on scientific merit and insight.…
IRS revokes exemption for a tuition-fundraising organization
The IRS revoked a charity's Section 501(c)(3) status after finding that its concession-stand fundraising primarily benefited participating families. Members worked at concession stands, accumulated…
IRS denies Section 501(c)(3) status to an anime convention
An organization already exempt under Section 501(c)(4) applied for recognition under Section 501(c)(3). Its main activity was an annual anime and pop-culture convention featuring panels and cultural…
Treasury-rate formula preserves a qualified structured settlement
A structured-settlement company assumed an insurer's obligation to make deferred payments for a minor's physical-injury claim and bought an annuity to fund those payments. The settlement called for…
IRS allows a timely revocation of a Section 83(b) election
A service provider made a Section 83(b) election for restricted employer stock and later asked the IRS for permission to revoke it. Such an election generally cannot be revoked without IRS consent,…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS grants extra time for a QSub election
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, or QSub, from the acquisition date. It failed to file Form 8869 on time…
IRS approves tax-free treatment for a corporate spin-off
A publicly traded corporation proposed separating one business into a newly formed controlled corporation. The plan included internal asset transfers, a contribution of subsidiary stock to the new…
IRS grants more time for a real-property business election
A foreign limited liability company treated as a partnership wanted to elect out of the Section 163(j) business-interest limit for its qualifying real-property trades or businesses. Its tax adviser…
IRS grants late disregarded-entity election relief
A parent company wholly owned a foreign eligible entity and intended to classify it as disregarded for federal tax purposes. Form 8832 was not filed on time because of inadvertence, although all…
IRS approves a school-construction set-aside
A private foundation requested approval to set aside funds for construction of a school building serving minority and underprivileged children. The multi-year project included classrooms, a welcome…
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.