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 1230002: IRS grants late election for tax-exempt controlled entity
The IRS granted a taxpayer permission to make a late election to avoid treatment as a tax-exempt entity for certain depreciation rules. The taxpayer was wholly owned by a tax-exempt housing…
PLR 1229009: IRS grants a 120-day extension to make a partnership § 754 election
The IRS granted a partnership an additional 120 days to make a § 754 election for a specified taxable year and later years. The partnership had relied on its tax advisor to make the election but…
PLR 1229006: IRS grants more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to make the election effective…
PLR 1229001: IRS grants extra time to waive a consolidated NOL carryback
The IRS granted a consolidated group an extension of time to file an election waiving the entire carryback period for a consolidated net operating loss. The group had intended to make the election…
PLR 1228032: IRS grants 120-day extension to elect disregarded-entity status
A domestic corporation asked for more time to elect to treat a foreign subsidiary as disregarded for federal tax purposes. The corporation said it had intended the election to be effective on an…
PLR 1228031: IRS grants 120-day extension to elect disregarded-entity status
A domestic corporation asked for more time to elect to treat a foreign subsidiary as disregarded for federal tax purposes. The corporation said it had intended the election to be effective on an…
PLR 1228008: IRS grants more time for a consolidated NOL carryback election
A consolidated corporate group missed the election to carry back a consolidated net operating loss for an extended period under IRC § 172(b)(1)(H). The IRS found that the group acted reasonably and…
PLR 1228007: IRS grants a consolidated group more time to make an extended 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. The IRS found that the group acted reasonably and in good…
PLR 1228006: IRS allows late entity classification and S corporation elections
A newly formed limited liability company intended to be treated as a corporation and to elect S corporation status for federal tax purposes. It failed to timely file both Form 8832, the entity…
PLR 1228005: IRS grants more time to waive the carryback period for a consolidated NOL
A corporation that became part of another consolidated group failed to timely elect to waive the entire carryback period for a consolidated net operating loss. The IRS found that the former common…
PLR 1228004: IRS grants a consolidated group more time to make an extended 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. The IRS found that the group acted reasonably and in good…
PLR 1227008: IRS grants more time to recharacterize ineligible Roth IRA conversions
An individual converted amounts from a traditional IRA to a Roth IRA in 2008 and 2009. Later, additional dividend income caused the individual's modified adjusted gross income to exceed the limit…
PLR 1226038: IRS denies extra time to recharacterize Roth IRA conversions
The IRS denied a married couple's request for 60 additional days to recharacterize three Roth IRA conversions as traditional IRAs. An IRS audit had disallowed listed-transaction losses and treated…
PLR 1226020: IRS grants more time to elect an extended NOL carryback
The IRS grants a consolidated corporate group an extension of time to elect an extended carryback period for a consolidated net operating loss. The group showed that it acted reasonably and in good…
PLR 1226017: IRS grants late entity-classification and S election relief
The IRS grants a limited liability company 120 days to make a late election to be treated as an association taxable as a corporation for federal tax purposes. It also grants relief for a late S…
PLR 1226014: IRS grants time to file an entity classification election
The IRS grants a foreign eligible entity 120 days to file Form 8832 and make an entity classification election, based on a finding that the taxpayer acted reasonably and in good faith and that…
PLR 1226012: IRS grants six foreign companies more time to file entity classification elections
Six foreign companies intended to be treated as corporations from their formation dates but inadvertently failed to file Form 8832. The IRS concluded that the requirements for relief under the…
PLR 1226010: IRS grants more time for Canadian RRSP treaty elections
Two married taxpayers asked for more time to elect under Rev. Proc. 2002-23 to defer U.S. income taxation on earnings in Canadian Registered Retirement Savings Plans under Article XVIII(7) of the…
PLR 1226009: IRS grants more time to file an original Form 3115
A consolidated group's parent asked for more time to attach an original Form 3115 to a subsidiary's timely filed federal income tax return. The subsidiary had changed the number and composition of…
PLR 1226008: IRS grants more time for an extended CNOL carryback election
A consolidated group's common parent failed to timely make an election to carry back a consolidated net operating loss for an extended period under § 172(b)(1)(H). The parent relied on a qualified…
PLR 1226007: IRS grants more time to file Form 3115 for abandoned lease improvements
An affiliated group asked for more time to file Form 3115 to change its accounting method for lessee improvements abandoned when leases terminated. The group had instructed a courier to send the…
PLR 1226006: IRS grants more time for an extended CNOL carryback election
A consolidated group's common parent failed to timely make an election to carry back a consolidated net operating loss for an extended period under § 172(b)(1)(H). The parent relied on qualified tax…
PLR 1226005: IRS grants more time to file Form 3115 for abandoned lease improvements
A taxpayer asked for more time to file Form 3115 to change its accounting method for lessee improvements abandoned when a lease terminated. The taxpayer had instructed a courier to send the form by…
PLR 1225006: IRS grants more time for two QSub elections
An S corporation asked for more time to elect to treat two wholly owned subsidiaries as qualified subchapter S subsidiaries. The elections were late because the taxpayer inadvertently failed to file…
PLR 1225002: IRS grants more time for a Canadian RRSP election
A U.S. resident asked for more time to make an election under Rev. Proc. 2002-23 for a Canadian registered retirement savings plan. The taxpayer had established the plan before becoming a U.S.…
PLR 1225001: IRS grants late entity-classification and S-election relief
An LLC asked for more time to elect corporate tax classification and for relief to make a late S corporation election. The IRS concluded that the taxpayer satisfied the reasonable-cause and…
PLR 1224028: IRS allows late revocation of an investment-income election
The IRS granted an individual taxpayer 60 days to revoke an election that treated qualified dividends and net capital gains as investment income under IRC § 163(d)(4)(B). The taxpayer's former…
PLR 1224027: IRS allows late revocation of an investment-income election
The IRS granted an individual taxpayer 60 days to revoke an election that treated qualified dividends and net capital gains as investment income under IRC § 163(d)(4)(B). The taxpayer's former…
PLR 1224025: IRS grants extra time to elect IC-DISC status
The IRS granted a corporation 60 days to file Form 4876-A and make a late election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The corporation formed…
PLR 1224024: IRS treats a late Form 1128 as timely filed
The IRS granted a C corporation relief for a late Form 1128 requesting a change in its annual accounting period. The taxpayer missed the filing deadline because of a clerical error, but represented…
PLR 1224022: IRS grants foreign entities more time to elect disregarded status
The IRS granted three foreign limited liability companies 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities missed the filing deadline…
PLR 1224021: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224020: IRS grants more time to elect disregarded-entity status
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity missed the filing deadline for its…
PLR 1224019: IRS grants more time for a late special-use valuation election
The IRS granted an estate 120 days to make an election under IRC § 2032A to specially value qualified farmland and related structures. The executor did not include the election on the estate's…
PLR 1224017: IRS grants more time to file an accounting-method change
The IRS granted an affiliated group 60 days to file the original and signed duplicate copies of Form 3115 for a change in the amortization method for certain assets. The group had filed its…
PLR 1224016: IRS grants more time to file a depreciation-method change
The IRS granted an affiliated group 60 days to file the original and signed duplicate copies of Form 3115 for a change in the depreciation method for certain assets. The group had filed its…
PLR 1224015: IRS allows a late Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to make a late election to defer U.S. federal income tax on income accruing in one Canadian Registered Retirement Savings Plan. An accounting firm had filed the…
PLR 1224010: IRS grants more time for a foreign disregarded-entity election
The IRS granted a domestic corporation 120 days to file Form 8832 for its wholly owned foreign subsidiary and elect to treat the subsidiary as a disregarded entity effective on its formation date.…
PLR 1224009: IRS grants more time for a foreign disregarded-entity election
The IRS granted foreign subsidiary Y 120 days to file Form 8832 and elect to be treated as a disregarded entity effective on its formation date. Y had missed the filing deadline, while its parent,…
PLR 1224008: IRS grants more time for a foreign partnership election
The IRS granted foreign company X 120 days to file Form 8832 and elect to be treated as a partnership effective on a specified earlier date. X had been classified by default as an association and…
PLR 1224005: IRS allows late filing of accounting-method forms
The IRS granted a taxpayer 30 days to attach the original Forms 3115 to the correct tax return for two accounting-method changes. The taxpayer had attached the forms to an earlier year's return even…
PLR 1224003: IRS allows a late extended NOL carryback election
The IRS granted a consolidated group 60 days to make a late election under IRC § 172(b)(1)(H) to carry back a consolidated net operating loss for an extended period. The parent had intended to make…
PLR 1224002: IRS allows late filing of a duplicate Form 3115
The IRS granted a taxpayer 30 days to file a signed duplicate Form 3115 with the IRS Ogden office. The taxpayer had timely attached the original form to its return but mailed the required duplicate…
PLR 1223011: IRS allows late homeowners association elections
The IRS granted a homeowners association 120 days to make late elections under IRC § 528 for two taxable years. The association's CPA firm had filed Forms 1120 instead of the required Forms 1120-H.…
PLR 1223010: IRS grants ten foreign entities more time to elect disregarded status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1223009: IRS grants ten foreign entities more time to elect partnership status
The IRS granted ten foreign entities 120 days to file Form 8832 elections to be treated as partnerships for federal tax purposes. Each entity had missed the filing deadline for its intended…
PLR 1223005: IRS allows a late low-income housing credit election
The IRS granted a taxpayer 120 days to correct Forms 8609 and elect to begin the low-income housing credit period in the year after a building was placed in service. An accountant had inadvertently…
PLR 1223004: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
PLR 1223003: IRS allows a late election to waive an NOL carryback
The IRS granted a consolidated group 45 days to make a late election to relinquish the entire carryback period for a consolidated net operating loss. The parent had intended to file the election but…
PLR 1222033: IRS grants extensions to allocate GST exemption to a trust
The IRS granted a husband and wife 120-day extensions to allocate their available generation-skipping transfer tax exemptions to an irrevocable trust. Their accountant had prepared gift tax returns…
PLR 1222030: IRS grants more time to waive a consolidated NOL carryback
The IRS granted a parent corporation an extension to file an election waiving the entire carryback period for a consolidated net operating loss. The parent intended to make the election with its…
PLR 1222028: IRS treats late REIT elections as timely made
The IRS granted two companies an extension of time to make elections under section 856(c) to be treated as real estate investment trusts for a specified tax year. The companies discovered that the…
PLR 1222023: IRS grants late entity-classification and S corporation relief
The IRS granted a limited liability company more time to elect to be treated as an association taxable as a corporation and also allowed a late S corporation election. The company had intended to be…
PLR 1222022: IRS grants more time to waive bonus depreciation
The IRS granted a limited partnership 60 days to make an election not to claim 50-percent additional first-year depreciation for specified classes of qualified property. The partnership had filed…
PLR 1222021: IRS grants more time to defer tax on Canadian retirement savings
The IRS granted a U.S. resident 60 days to make an election under Rev. Proc. 2002-23 for deferral of U.S. federal income tax on income accruing in a Canadian Registered Retirement Savings Plan. The…
PLR 1222019: IRS grants more time for two taxpayers to defer Canadian RRSP income
The IRS granted a married couple 60 days to make elections under Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in their Canadian Registered Retirement Savings Plans. The couple had…
PLR 1222013: IRS grants more time to allocate GST exemption to three trusts
The IRS granted a taxpayer 120 more days to allocate generation-skipping transfer tax exemption to transfers made to three irrevocable trusts. The taxpayer's accounting firm prepared and filed the…
PLR 1222012: IRS grants more time to make a section 754 election
The IRS granted a limited liability company more time to make a section 754 election for the taxable year in which a partner died. The election had been omitted from the partnership return even…
PLR 1221012: IRS grants more time for a rental real estate election
The IRS granted married taxpayers 120 additional days to make an election under IRC § 469(c)(7)(A) to treat all of their interests in rental real estate as one rental real estate activity. The…
PLR 1221005: IRS grants more time to elect corporate tax classification
The IRS granted a limited liability company 120 additional days to file Form 8832 and elect to be treated as a corporation for federal tax purposes. The company had intended to be classified as a…
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.