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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 1150011: 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 1150010: 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 1150009: 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 1150008: 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 1150007: 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 1150006: 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 1150005: 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 1150004: 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 1150003: 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 1150002: 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 1150001: 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…
IRS granted more time for a consolidated-loss carryback waiver election
The IRS granted an acquiring group an extension of time to file an election relinquishing the carryback period for consolidated net operating losses attributable to a target corporation. The…
IRS granted more time for a section 168 election
The IRS granted a subchapter S corporation an extension of time to make an election under section 168(h)(6)(F)(ii), which would allow it not to be treated as a tax-exempt entity for the alternative…
IRS granted more time for a section 198 remediation election
The IRS granted a taxpayer 60 days to make a section 198 election to deduct qualified environmental remediation expenditures for an earlier tax year. The taxpayer had relied on an accountant who did…
Section 301.9100-3 cannot extend this statutory NOL election
The IRS denied taxpayers’ request for more time to make a section 172(b)(1)(H) net operating loss carryback election. It concluded that the election was statutory because its due date was set by the…
IRS granted more time for a section 754 election
The IRS granted a partnership 120 days to make a late section 754 election to adjust the basis of partnership property. The partnership return had been timely filed, but the election was…
IRS granted more time for a section 754 election
The IRS granted a partnership 120 days to make a late section 754 election to adjust the basis of partnership property. The partnership return had been timely filed, but the election was…
IRS granted late foreign-entity classification elections
The IRS granted eight foreign entities 120 days to file late Form 8832 entity-classification elections. The entities had failed to file the forms due to inadvertence. The IRS found that the…
IRS grants a partnership 120 days to make a late Section 754 election
The IRS granted a partnership an additional 120 days to make a late election under IRC § 754 to adjust the basis of partnership property. The partnership had inadvertently failed to make the…
IRS grants time for QTIP trust division and reverse QTIP election
The IRS granted an estate 120 days to elect to treat an existing QTIP trust as two separate trusts, an exempt QTIP trust and a non-exempt QTIP trust. It also granted 120 days to make a reverse QTIP…
IRS grants time to allocate GST exemption to a trust
The IRS granted a husband and wife an additional 120 days to allocate their generation-skipping transfer tax exemptions to a prior gift to a trust. The couple had timely filed their gift-tax…
PLR 1147022: IRS grants extra time to make an IC-DISC election
A corporation asked the IRS for more time to file Form 4876-A, the election required for IC-DISC treatment. The corporation had intended to operate as an IC-DISC, but its accounting and law firms…
PLR 1147021: IRS grants extra time to waive a consolidated group's NOL carryback
A consolidated corporate group asked the IRS for more time to elect to relinquish the entire carryback period for a consolidated net operating loss. The group intended to make the election but…
PLR 1147019: IRS grants extra time to claim a consolidated-group stock loss
A consolidated group asked the IRS for more time to file the statement needed to claim a loss on its subsidiary's stock under Treas. Reg. § 1.337(d)-2(c). The statement was required with the group's…
PLR 1147011: IRS grants extra time for a QSub election
An S corporation acquired all of the stock of another S corporation and intended to treat the subsidiary as a qualified subchapter S subsidiary. The parent did not timely file Form 8869, the QSub…
PLR 1147009: IRS allows late reverse QTIP and split-trust elections
An estate made a QTIP election for a marital trust but did not make a reverse QTIP election or affirmatively allocate the decedent's generation-skipping transfer tax exemption. The estate also…
PLR 1147004: IRS grants extra time for a partnership classification election
An LLC asked the IRS for more time to file Form 8832 and elect partnership classification for federal tax purposes. The LLC had changed ownership and was eligible to make the election, but no…
PLR 1147002: IRS grants late election for disregarded-entity treatment
A foreign corporation with one owner asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The corporation had failed to file the form by…
PLR 1146015: IRS grants extra time for a consolidated group to make an extended CNOL carryback election
The IRS granted a consolidated corporate group 60 days to make a late election to carry back an applicable consolidated net operating loss beyond the normal two-year period. The group had failed to…
PLR 1146013: IRS grants extra time to elect an extended CNOL carryback period after a prior waiver
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 had previously elected to relinquish the entire…
PLR 1146012: IRS grants extra time for a REIT election filed with an improperly signed return
The IRS granted a trust an extension of time to make a regulatory election to be treated as a real estate investment trust. The trust's Form 1120-REIT had been signed and filed by an officer of its…
PLR 1146007: IRS grants extra time for a newly formed group to file a consolidated return
The IRS granted a newly formed affiliated group 45 days to make a late election to file a consolidated federal income tax return with a new parent as the common parent. The group intended to make…
PLR 1146006: IRS grants extra time for a parent to file a consolidated return after an acquisition
The IRS granted a parent 45 days to make a late election to file a consolidated federal income tax return after an acquisition changed the affiliated group's common parent. The parent and three…
PLR 1146004: IRS grants more time for a foreign LLC to elect its tax classification
The IRS granted a foreign limited liability company 120 days to file Form 8832 and elect a federal tax classification different from its default classification. The company had inadvertently missed…
PLR 1145033: IRS grants time to recharacterize an ineligible Roth IRA conversion
The IRS granted an individual 60 days to recharacterize an amount converted from a traditional IRA to a Roth IRA as a contribution to a traditional IRA. The taxpayer had relied on incorrect…
Taxpayer granted 60 days to file an omitted original Form 3115
The IRS considered a request for more time to file an original Form 3115, which is used to request a change in accounting method. The taxpayer had timely filed a signed duplicate with the IRS…
Parent granted 45 days to make a controlled-group value-restoration election
The IRS granted a parent company and certain foreign subsidiaries additional time to make an election to restore value under the controlled-group limitation rules of IRC § 382. The taxpayers had…
PLR 1144026: IRS grants more time to allocate generation-skipping transfer tax exemptions
The IRS granted a husband and wife 120 more days to allocate their available generation-skipping transfer tax exemptions to gifts made to two trusts. The couple had elected to split their gifts, but…
PLR 1144022: IRS grants more time to make taxable REIT subsidiary elections
The IRS granted a company and two subsidiaries 60 days to make elections treating the subsidiaries as taxable REIT subsidiaries of the company, effective as of a specified merger date. Before the…
PLR 1144021: IRS grants more time to waive a consolidated net operating loss carryback
The IRS granted a consolidated group 45 days to file an election waiving the entire carryback period for a consolidated net operating loss. The election had not been timely filed even though the…
PLR 1144020: IRS grants more time to waive a consolidated net operating loss carryback
The IRS granted a consolidated group 45 days to file an election waiving the entire carryback period for consolidated net operating losses. The election had not been timely filed even though the…
PLR 1144019: IRS grants late-filing relief for a Form 1128 tax-year change
The taxpayers asked the IRS to treat a late Form 1128 as timely. The form sought to change their federal tax year from a November 30 year-end to a December 31 year-end. The IRS found that they acted…
PLR 1144012: IRS grants late entity-classification and S corporation election relief
The taxpayer, a limited liability company, asked for more time to elect corporate tax classification and relief for a late S corporation election. The IRS granted 120 days to file Form 8832…
PLR 1144011: IRS grants more time for an estate's alternate valuation election
An estate asked for more time to make the alternate valuation election under § 2032 after its attorney failed to advise the executrix about the election. The IRS found that the estate met the…
PLR 1144007: IRS grants late election relief for a taxable REIT subsidiary
A REIT and its subsidiary asked for more time to file Form 8875, the joint election to treat the subsidiary as a taxable REIT subsidiary. The election was missed after the responsible officer left…
PLR 1144004: IRS grants late election relief for post-October capital losses
A regulated investment company asked for more time to elect to defer all or part of its post-October capital losses when computing taxable income and net capital gain. Its accounting firm had…
PLR 1143017: IRS grants more time to elect out of the bankruptcy ownership-change rules
The IRS granted a corporate taxpayer 45 days to file a regulatory election under § 1.382-9(i) not to apply the special § 382(l)(5) rules after an ownership change in a title 11 case. The election…
PLR 1143015: IRS grants more time to file a consolidated return election
The IRS granted an affiliated group 45 days to make a late election to file a consolidated federal income tax return with Parent as the common parent. The group had not filed a valid election by the…
PLR 1143013: IRS grants extra time to file an election related to a subsidiary stock loss
A consolidated group sold the stock of a wholly owned subsidiary and was required to file a regulatory statement to elect recognition of the resulting loss. The statement was not timely filed. The…
PLR 1143006: IRS grants more time to make a consolidated-group NOL carryback election
A corporation acquired a group of subsidiaries and needed to make an election affecting whether net operating losses attributable to those subsidiaries could be carried back to their former…
PLR 1143004: IRS grants more time to make an investment-income election
An individual wanted to elect to treat qualified dividends and certain net capital gains as investment income for purposes of deducting investment interest expense. The election was not made on time…
PLR 1143001: IRS grants estates more time to allocate GST tax exemptions to trust transfers
Two spouses made transfers to an irrevocable trust but did not file the required gift tax returns for later transfers or allocate their generation-skipping transfer tax exemptions to those…
PLR 1142030: IRS waives the 60-day rollover deadline after an adviser opened the wrong account
An individual received distributions from two IRAs and intended to roll the funds into another IRA within 60 days. A financial adviser mistakenly checked the wrong box on the account application, so…
PLR 1142021: Late election relief granted for Canadian retirement accounts
A former Canadian resident who became a U.S. resident had two Canadian retirement accounts. The taxpayer's first accountant did not advise the taxpayer to make the election under the U.S.-Canada…
PLR 1142011: IRS grants late-filing relief for a tax-year change application
The IRS treated a corporation's late Form 1128 as timely under the rules for extensions of time for regulatory elections. The form requested a change from a September 30 tax year to a December 31…
PLR 1142004: IRS grants extra time to file an accounting-method change request
The IRS granted a taxpayer additional time to file Form 3115 with a federal income tax return. The form requested permission to change the taxpayer's accounting method for advance payments under the…
PLR 1141010: IRS grants more time to elect consolidated return filing
A corporate parent and its includible subsidiaries missed the deadline to elect to file a consolidated federal income tax return. The IRS found that the group acted reasonably and in good faith…
PLR 1141009: IRS grants more time to elect expiration of a subsidiary's loss carryovers
A parent of a consolidated group asked for more time to elect to treat a subsidiary's separate-return loss carryovers as expiring before the subsidiary joined the group. The election was not…
PLR 1141008: IRS grants more time to elect expiration of a subsidiary's loss carryovers
A parent of a consolidated group asked for more time to elect to treat a subsidiary's separate-return loss carryovers as expiring before the subsidiary joined the group. The election was not…
PLR 1141004: IRS grants time for environmental remediation elections
A real estate leasing company incurred qualified environmental remediation expenditures in two years but did not make the section 198 elections needed to deduct them in those years. It later claimed…
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.