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 1221003: IRS grants extra time to elect IC-DISC status
The IRS granted a taxpayer 60 additional days to file Form 4876-A and make an election to be treated as an interest charge domestic international sales corporation, or IC-DISC. The taxpayer had been…
PLR 1221001: IRS allows a late accounting-method change after unusual hardship
The IRS granted a taxpayer permission to file a late Form 3115 and request an accounting-method change for an earlier tax year. The taxpayer had missed the election connected to temporary…
PLR 1220025: Consolidated group receives more time to waive NOL carryback
The IRS granted a consolidated group an extension of time to file an election relinquishing the entire carryback period for a consolidated net operating loss. The parent intended to make the…
PLR 1220019: Consolidated group receives more time for extended NOL carryback
The IRS granted a consolidated group 60 days to file an election extending the carryback period for a consolidated net operating loss. The parent missed the deadline after relying on a qualified tax…
PLR 1220017: Estate receives more time to file a QDOT citizenship notice
The IRS granted a qualified domestic trust more time to file Form 706-QDT and notify the IRS that the surviving spouse had become a United States citizen. The spouse had continuously resided in the…
PLR 1220014: Taxpayer receives more time to elect RRSP income deferral
The IRS granted a U.S. citizen more time to elect deferral of U.S. income tax on earnings in a Canadian registered retirement savings plan. The taxpayer had relied on tax preparers who did not…
PLR 1220008: Taxpayer receives more time to allocate GST tax exemption to a trust transfer
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The taxpayer's accountant had failed to file the…
PLR 1220007: Taxpayer receives more time to allocate GST tax exemption to a trust transfer
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The taxpayer's accountant had failed to file the…
PLR 1220003: Consolidated group receives more time to elect an extended NOL carryback
The IRS granted a consolidated corporate group 60 additional days to elect an extended carryback period for a consolidated net operating loss. The group intended to make the election but did not…
PLR 1219037: IRS grants extra time to recharacterize a Roth IRA contribution
The taxpayer had a retirement plan containing traditional and Roth funds. When the plan was terminated, the plan administrator rolled both amounts into a traditional IRA, even though the Roth amount…
PLR 1219036: IRS waives rollover deadlines and grants recharacterization relief
The taxpayer asked the IRS to address several retirement-account errors made when financial-service personnel deposited funds into a Roth IRA instead of the intended traditional IRA. The IRS waived…
PLR 1219035: IRS grants extra time to recharacterize a Roth IRA
The taxpayer converted a traditional IRA to a Roth IRA after relying on an expected income level that was below the applicable conversion threshold. Revised partnership information later showed that…
PLR 1219005: Permission granted to revoke a capital-gain investment-income election
Taxpayers asked to revoke an election that treated capital gain as investment income under IRC § 163(d)(4)(B)(iii). Their tax professional had mistakenly reported personal-loan interest as…
PLR 1219004: IRS grants more time for a Canadian RRSP tax-deferral election
The IRS granted a taxpayer 60 days to elect to defer U.S. income taxation on income accrued in three Canadian Registered Retirement Savings Plans under Revenue Procedure 2002-23 and the U.S.-Canada…
PLR 1219002: IRS grants a married couple more time for Canadian RRSP elections
The IRS granted a married couple 60 days to make elections under Revenue Procedure 2002-23 to defer U.S. income tax on income accruing in their Canadian Registered Retirement Savings Plans. The…
PLR 1218037: IRS grants more time to recharacterize two Roth IRA conversions
A married couple asked for more time to recharacterize Roth IRA conversions after their tax advisor discovered that their modified adjusted gross income exceeded the limit for the relevant year. The…
IRS grants a company more time to elect REIT treatment
The IRS granted a company a 60-day extension to make an election under IRC § 856(c) to be treated as a real estate investment trust for a specified tax year. The company intended to make the…
IRS grants more time to elect the start of a low-income housing credit period
The IRS granted a taxpayer 120 days to make a late election under IRC § 42(f)(1) specifying when the credit period for a multifamily residential building would begin. The taxpayer had intended to…
IRS grants more time to elect QSub treatment
The IRS granted a corporation 120 days to elect to treat a wholly owned subsidiary as a qualified subchapter S subsidiary. The parent corporation had acquired all of the subsidiary’s stock and…
PLR 1217015: IRS grants more time for pollution-control-facility elections
An electric utility asked for more time to make regulatory elections under IRC section 169 for certified pollution control facilities. The utility had claimed amortization for several facilities but…
PLR 1217012: IRS grants more time to allocate generation-skipping transfer tax exemption
Trustees asked the IRS for more time to allocate a decedent's generation-skipping transfer tax exemption to two cash transfers made to an irrevocable trust. The decedent's accountants prepared the…
PLR 1217011: IRS grants time to sever a QTIP trust and make a reverse QTIP election
An estate asked for more time to divide a marital trust into a generation-skipping transfer tax exempt trust and a nonexempt trust, make a reverse QTIP election, and allow the decedent's unused GST…
PLR 1217004: IRS permits partial revocation of inadvertent investment-income elections
A trust inadvertently elected to treat more capital gain and qualified dividend income as investment income than was needed to support its investment-interest deduction. The error resulted from a…
PLR 1217003: IRS permits partial revocation of an inadvertent investment-income election
A trust inadvertently elected to treat qualified dividend income and net capital gain as investment income, even though the amount exceeded its investment-interest expense. The error resulted from a…
PLR 1217002: IRS grants extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership but inadvertently failed to file Form 8832. The IRS concluded that the requirements for relief under the section 9100 regulations…
CCA 1216037: Advice addresses late relief for an alternate-valuation election
Chief Counsel advice addresses whether a taxpayer may seek relief to make an IRC § 2032 alternate-valuation election more than one year after the return's due date. The advice says relief may be…
PLR 1216024: IRS grants more time for a partnership classification election
A foreign business entity intended to elect partnership classification for federal tax purposes but failed to timely file Form 8832. The IRS concluded that the requirements for relief under Treas.…
PLR 1216021: IRS grants a foreign entity more time to elect partnership classification
A foreign entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under the regulations were…
PLR 1216020: IRS grants more time to make a corporate classification election
A business entity formed under the laws of a redacted state intended to elect treatment as an association taxable as a corporation but did not timely file Form 8832. The IRS concluded that the…
PLR 1216018: IRS grants more time to file consolidated return elections
A parent corporation's consolidated group sold a subsidiary and failed to timely file elections intended to reduce possible duplication of losses and avoid reduction of tax attributes. The IRS…
PLR 1216015: IRS grants more time to elect qualified subchapter S subsidiary status
An S corporation acquired a wholly owned subsidiary and intended to elect qualified subchapter S subsidiary status for that subsidiary, but it did not timely file Form 8869. The IRS found that the…
PLR 1216014: IRS grants more time for a foreign entity to elect partnership status
A foreign limited liability partnership intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The entity had sold an interest in a domestic limited…
PLR 1216013: IRS grants more time to make an alternate valuation election
The co-executors of an estate timely filed Form 706 but did not make the alternate valuation election under IRC § 2032. They later determined that the election should have been made and filed a…
PLR 1216012: IRS grants more time for a foreign entity to elect partnership status
A foreign entity intended to be treated as a partnership for federal tax purposes but did not timely file Form 8832. The IRS concluded that the requirements for relief under Treas. Reg. § 301.9100-3…
PLR 1216006: IRS grants extra time to make an IC-DISC election
A domestic corporation asked for more time to file Form 4876-A, the form used to elect IC-DISC status, effective from its incorporation date. The corporation believed the form had been timely filed,…
PLR 1216004: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216003: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216002: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1216001: IRS grants extra time to make a disregarded-entity election
A foreign entity intended to elect disregarded-entity treatment for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
IRS approves an LLC's change to disregarded-entity status
The IRS consented to an LLC's request to change its federal tax classification from an association taxable as a corporation to a disregarded entity. The LLC had previously changed its classification…
IRS consents to an LLC's second classification change
The IRS consented to an LLC's request to change its federal tax classification from an association taxable as a corporation to a disregarded entity. The LLC had previously changed its classification…
IRS grants an LLC more time to elect corporate tax treatment
The IRS granted an LLC an extension of time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The LLC intended to make the election…
PLR 1214019: IRS grants more time to make an extended NOL carryback election
The IRS considered a consolidated group's request for more time to elect an extended carryback period for a consolidated net operating loss. The election had not been filed by its deadline because…
PLR 1214018: IRS grants more time to file a section 338 election
The IRS considered a request for more time to file a section 338 election after a foreign purchasing corporation acquired all of the stock of a controlled foreign corporation. The election was…
PLR 1214016: IRS grants more time for one homeowners association election year
The IRS considered a homeowners association's request to make late elections under IRC § 528 for two taxable years. The association had filed Forms 1120 instead of Forms 1120-H after relying on an…
PLR 1214006: IRS grants more time to make a section 754 election
The IRS considered a limited partnership's request for more time to make a section 754 election after interests in the partnership were sold and transferred. The partnership's tax advisors had not…
PLR 1214004: IRS permits partial revocation of an investment income election
The IRS considered a trust's request to partially revoke an election that treated net capital gain and qualified dividend income as investment income for purposes of the investment interest…
PLR 1214002: IRS grants late taxable REIT subsidiary election relief
The IRS considered a REIT and its wholly owned subsidiary's request for more time to elect taxable REIT subsidiary status. The company's accountant mistakenly believed the election could be filed…
PLR 1213024: IRS grants 120 days to make a late section 754 election
The IRS granted a partnership 120 days to make a late election under IRC § 754 for a specified taxable year. The partnership's tax adviser had inadvertently failed to make the election on time after…
PLR 1213017: IRS grants time to elect disregarded-entity status
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. The entity was wholly owned by one person and had intended to…
PLR 1213015: IRS grants late relief for a foreign entity's partnership election
The IRS granted a foreign eligible entity 120 days to file Form 8832 electing partnership treatment for federal tax purposes. The entity intended to make that election effective on a specified date,…
PLR 1213014: IRS grants extra time for a Canadian RRSP treaty election
The IRS granted a taxpayer 60 days to elect treaty treatment that defers U.S. tax on income accruing but not distributed by a Canadian registered retirement savings plan. The taxpayer became a U.S.…
PLR 1213009: IRS grants late entity-classification and S-election relief
The IRS granted a limited liability company 120 days to file Form 8832 electing association treatment as a corporation for federal tax purposes. The company had also failed to timely file Form 2553…
PLR 1213008: IRS permits partial revocation of an investment-income election
The IRS consented to a trust's partial revocation of an election to treat net capital gain as investment income for purposes of the investment-interest deduction. A tax-preparation software error…
PLR 1213007: Foreign entity gets extra time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity 120 days to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The entity was formed in a foreign country and was…
PLR 1213006: IRS grants extra time for a section 754 election
The IRS granted a limited partnership 120 days to make a late section 754 election for the specified year. Transfers of partnership interests had caused a technical termination, but the partnership…
PLR 1212007: IRS grants extra time to elect exclusion of qualified real property business indebtedness income
The IRS granted a taxpayer an additional 45 days to file an amended return and make an election under IRC § 108(c)(3)(C) to exclude income from the discharge of qualified real property business…
PLR 1212006: IRS grants extra time for a partner to make a section 108 election
The IRS granted the taxpayer an additional 45 days to file an amended return and make an election under IRC § 108(c)(3)(C) to exclude income from the discharge of qualified real property business…
PLR 1212005: IRS grants extra time for a partner to make a section 108 election
The IRS granted the taxpayer an additional 45 days to file an amended return and make an election under IRC § 108(c)(3)(C) to exclude income from the discharge of qualified real property business…
PLR 1212004: IRS grants extra time for a partner to make a section 108 election
The IRS granted the taxpayer an additional 45 days to file an amended return and make an election under IRC § 108(c)(3)(C) to exclude income from the discharge of qualified real property business…
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.