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 1212003: 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 1212002: 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 1210021: Late taxable REIT subsidiary election granted a reasonable extension
The IRS granted a REIT and its wholly owned subsidiary an extension of time to make a joint election treating the subsidiary as a taxable REIT subsidiary. The companies intended the election to take…
PLR 1210013: Taxpayer receives more time to elect treaty deferral for Canadian RRSP income
The IRS granted a taxpayer an extension of time to make an election under the U.S.-Canada Income Tax Treaty and Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in three Canadian…
PLR 1210011: IRS grants more time for depreciation and drilling-cost elections
The IRS granted an affiliated corporate group 60 days to make late elections to use the alternative depreciation system and not claim additional first-year depreciation for specified property. It…
PLR 1210009: Taxpayer receives more time to make a Canadian RRSP election
The IRS granted a taxpayer 60 days to make an election under the U.S.-Canada Income Tax Convention and Rev. Proc. 2002-23 to defer U.S. income tax on income accruing in a Canadian registered…
PLR 1210007: Homeowners association receives more time to elect § 528 treatment
The IRS granted a homeowners association 120 days to file Forms 1120-H and make its election to be treated under IRC § 528 for two taxable years. The association had relied on an independent CPA…
PLR 1210006: IRS denies relief for late net operating loss carryback election
The IRS denied a taxpayer's request for more time to elect the extended net operating loss carryback under IRC § 172(b)(1)(H). The taxpayer had relied on a tax professional who did not explain the…
PLR 1208033: IRS grants extra time to make a LIFO inventory election
A parent corporation failed to attach Form 970 when a newly acquired subsidiary first began using the LIFO inventory method. The group later discovered the omission while reviewing its financial…
PLR 1208032: IRS grants extra time to elect an extended net operating loss carryback
A consolidated corporate group incurred a net operating loss and missed the deadline to elect an extended carryback period. The parent requested relief after relying on a tax professional who failed…
PLR 1208022: IRS grants extra time for a qualified subchapter S subsidiary election
The IRS granted a corporation 120 days to file Form 8869 and elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent intended the election to be effective when…
PLR 1208020: IRS grants late disregarded-entity classification election
The IRS granted a foreign single-owner entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended the classification to apply…
PLR 1208012: IRS grants more time for four companies to elect REIT status
The IRS granted four companies an extension of time to elect REIT status under IRC § 856(c). The companies had been treated as qualified REIT subsidiaries on their parent’s returns even after…
PLR 1208011: IRS grants more time for five QSub elections
The IRS granted an S corporation an extension of time to elect to treat five wholly owned subsidiaries as qualified subchapter S subsidiaries. The taxpayer said its representative prepared and…
PLR 1208010: IRS approves a late change to entity classification
The IRS consented to a foreign eligible entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity represented that a change in…
PLR 1208009: IRS approves a late change to entity classification
The IRS consented to a foreign eligible entity changing its federal tax classification from a disregarded entity to an association taxable as a corporation. The entity represented that a change in…
PLR 1208001: IRS grants late-election relief for a consolidated group's net operating loss
The IRS granted a parent corporation additional time to file an election giving up the entire net operating loss carryback period for its consolidated group's loss. The election had not been filed…
PLR 1207003: IRS granted more time to apportion a consolidated section 382 limitation
The IRS granted a parent corporation and a subsidiary 45 days to file an election apportioning a consolidated IRC § 382 limitation to the subsidiary. The election had been required with a…
PLR 1206013: Extension granted to file an entity classification election
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity intended to make the election effective…
PLR 1206012: Extension granted to elect association treatment for federal tax purposes
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect to be treated as an association taxable as a corporation. The entity was eligible to make the election but…
PLR 1206010: Extension granted to make a late section 338(g) election
The IRS granted a parent corporation 45 days to file a late section 338(g) election concerning a foreign subsidiary's purchase of a target corporation's stock. The parent showed that it reasonably…
PLR 1206008: Extension granted for a late disregarded-entity election
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded from its owner for federal tax purposes. The entity was eligible to make the election…
PLR 1206007: Extension granted for a late disregarded-entity election
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded from its owner for federal tax purposes. The entity was eligible to make the election…
PLR 1206006: Extension granted for an extended CNOL carryback election
The IRS granted a consolidated group 60 days to make a late election for an extended carryback period for a consolidated net operating loss. The group sought to carry back the loss for more years…
PLR 1206002: Extension granted to correct a low-income housing election
The IRS granted a low-income housing project 120 days to correct an election that was mistakenly reported on Form 8609. The taxpayer intended to elect the 20 percent at 50 percent income set-aside…
PLR 1205003: IRS grants extra time to elect out of additional first-year depreciation
The IRS granted an affiliated group an extension of time to elect not to claim additional first-year depreciation under IRC § 168(k). The group had timely filed its consolidated returns but…
PLR 1204027: IRS grants extra time to recharacterize an ineligible Roth IRA conversion
The IRS granted a married couple up to 60 days to recharacterize a Roth IRA conversion that they were not eligible to make because their modified adjusted gross income exceeded the applicable limit.…
PLR 1202019: IRS grants a trust more time to elect a charitable deduction
The IRS granted a trust an extension of time to make an election under IRC section 642(c)(1). The election would treat charitable contributions paid to a tax-exempt foundation in a later tax year as…
PLR 1202017: IRS grants more time for a tax-exempt controlled entity election
The IRS granted a limited liability company 60 more days to make an election under IRC section 168(h)(6)(F)(ii). The election allowed the company, which was owned by a tax-exempt governmental…
PLR 1202015: IRS grants more time for a disregarded-entity election
The IRS granted a foreign entity 120 more days to elect to be treated as disregarded from its owner for federal tax purposes. The entity was wholly owned by another entity and was eligible to make…
PLR 1202013: IRS grants late entity classification elections
The IRS granted three foreign entities 120 more days to file late entity classification elections. Two entities were allowed to elect partnership status, and a third was allowed to elect…
PLR 1202005: IRS denies late election relief for an NOL carryback
The IRS denied a request for additional time to elect an extended net operating loss carryback under IRC § 172(b)(1)(H). The taxpayers had directed their accounting firm to make the election, but…
PLR 1201015: IRS treats late Form 1128 as timely filed
The IRS granted a taxpayer relief for filing Form 1128 late when changing its annual accounting period. The taxpayer sought to change from a June 30 year-end to a December 31 year-end and filed the…
PLR 1201014: IRS grants partnership 120 days to make a section 754 election
The IRS granted a state limited partnership 120 days to make a late election under IRC section 754. The partnership had timely filed its tax return but inadvertently omitted the election to adjust…
PLR 1201011: IRS grants 45 days to make consent dividend elections
The IRS granted a limited liability company 45 days to file the forms needed to make consent dividend elections for three taxable years. The taxpayer had been advised that it might be a personal…
PLR 1201010: IRS grants more time for a bank-affiliate disaffiliation election
The IRS granted a bank holding company 90 days to make an election to disaffiliate a failed bank subsidiary from its consolidated tax group. The state banking department had placed the institution…
PLR 1201008: IRS grants more time for a partnership basis election
The IRS granted a lower-tier partnership 120 days to make a late IRC § 754 election. An upper-tier partnership had acquired an interest in the lower-tier partnership, and the lower-tier partnership…
PLR 1201007: IRS grants more time for a late section 754 election
The IRS granted a partnership 120 days to make a late IRC § 754 election. The partnership had timely filed its tax return but inadvertently did not include the election to adjust the basis of…
PLR 1152009: IRS grants more time to file an extended NOL carryback election
The IRS granted a consolidated group an extension of time to file an election for an extended carryback period for a consolidated net operating loss. The group had failed to make the election by the…
PLR 1152007: IRS grants more time for a PFIC mark-to-market election
The IRS granted two regulated investment funds an additional 60 days to make an IRC § 1296 mark-to-market election for shares of a passive foreign investment company. The funds relied on…
PLR 1152004: IRS grants more time to allocate GST exemption to a trust transfer
The IRS granted an estate executor and a surviving spouse 120 additional days to allocate generation-skipping transfer tax exemption to a transfer made to an irrevocable trust. The taxpayers had…
PLR 1151018: IRS grants relief for a late Form 1128
The IRS granted relief to a taxpayer that filed Form 1128 late to change its tax year from an October 31 year-end to a December 31 year-end. The IRS concluded that the taxpayer acted reasonably and…
PLR 1151016: IRS grants time to revoke investment-income elections
The IRS granted a taxpayer an additional 60 days to revoke elections that treated qualified dividends and capital gains as investment income for two prior tax years. The taxpayer had relied on a tax…
PLR 1151014: IRS grants time to make a late Section 754 election
The IRS granted a partnership an additional 60 days to make an IRC § 754 election after two members acquired another member's interest. The partnership had timely filed its return but inadvertently…
PLR 1151012: IRS grants time for a controlled-group value-restoration election
The IRS granted a parent and related foreign subsidiaries 45 days to file a late election under Treas. Reg. § 1.382-8(h) to restore value reduced after an ownership change. The taxpayers represented…
PLR 1151011: IRS grants time to make a late Section 754 election
The IRS granted a limited partnership an additional 60 days to make a late IRC § 754 election to adjust the basis of partnership property. The partnership had filed later returns consistent with the…
PLR 1151010: IRS grants time to elect disregarded-entity treatment
The IRS granted a foreign business 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 a husband and wife as…
PLR 1151007: IRS grants time to allocate GST exemption to a trust transfer
The IRS granted a taxpayer 120 days to allocate generation-skipping transfer tax exemption to a prior transfer to an irrevocable trust. The taxpayer had timely reported the transfer but the…
PLR 1151003: IRS grants time for an alternate valuation election
The IRS granted an estate an extension through the date a supplemental Form 706 was filed to make an alternate valuation election under IRC § 2032. The executor had timely filed the original return…
PLR 1150028: IRS granted extra time to file LIFO inventory elections
The IRS granted a parent company and a subsidiary an extension of time to file Forms 970 to elect the LIFO inventory method. The taxpayers had used LIFO after failing to make the required elections…
PLR 1150027: IRS allowed a late election for a tax-exempt controlled entity
The IRS granted a tax-exempt controlled entity extra time to elect to be treated as a taxable entity for purposes of the tax-exempt use property rules. The taxpayer had attached the election to the…
PLR 1150025: IRS granted extra time to file LIFO inventory elections
The IRS granted a parent company and its subsidiaries an extension of time to file Forms 970 to elect the LIFO inventory method. The taxpayers had used LIFO after failing to make the required…
PLR 1150022: IRS allowed a late taxable REIT subsidiary election
The IRS granted a REIT and its subsidiary extra time to elect to treat the subsidiary as a taxable REIT subsidiary. The election was missed because the company relied on tax professionals and…
PLR 1150018: IRS granted extra time to allocate GST exemption to a trust transfer
The IRS considered a taxpayer's request for more time to allocate generation-skipping transfer tax exemption to a transfer of property and cash to an irrevocable trust. The taxpayer timely reported…
PLR 1150017: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150016: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150015: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150014: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150013: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
PLR 1150012: IRS granted extra time for a foreign entity classification election
The IRS considered a foreign eligible entity's request to elect disregarded-entity status for federal tax purposes. The entity intended to make the election effective on a specified date, but Form…
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.