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 1141003: IRS grants more time to elect IC-DISC status
A domestic corporation intended to elect interest charge domestic international sales corporation status for its first taxable year but did not timely file Form 4876-A. The corporation relied on its…
PLR 1141002: IRS grants more time for a section 754 election
A partnership missed the deadline to make a section 754 election after the death of a partner and the transfer of that partner's interest. The partnerships represented that they relied on a tax…
PLR 1141001: IRS grants more time for a section 754 election
A partnership missed the deadline to make a section 754 election after the death of a partner and the transfer of that partner's interest. The partnership represented that it relied on a tax…
PLR 1140030: IRS grants time to file a qualified separate line of business election
A company asked for more time to file Form 5310-A and make a qualified separate line of business election for a testing year. The request arose after the company learned that a wholly owned…
PLR 1140016: Corporation granted more time to request a dual consolidated loss closing agreement
A successor corporation asked for extra time to request a closing agreement related to dual consolidated losses after a restructuring moved corporations from one consolidated group to another. The…
PLR 1140014: LLC receives relief for late entity-classification and S corporation elections
An LLC asked for relief after failing to timely file elections to be treated as a corporation and as an S corporation for federal tax purposes. The IRS granted the LLC 120 days to file Form 8832 and…
PLR 1140011: Parent granted more time to elect an extended CNOL carryback
The common parent of a consolidated group asked for extra time to elect an extended carryback period for a consolidated net operating loss. The group missed the filing deadline for the election…
PLR 1140007: Consolidated group granted more time to elect an extended NOL carryback
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The election was not timely filed because the group relied on a…
PLR 1140003: REIT granted more time to make a consent dividend election
A real estate investment trust asked for more time to make a consent dividend election after its tax return included forms with the wrong entities identified as the shareholder and corporation. The…
PLR 1140001: QDOT trustee granted more time to report beneficiary citizenship
A qualified domestic trust trustee asked for more time to notify the IRS and certify that the surviving spouse beneficiary had become a United States citizen. The notice was missed because the law…
PLR 1138031: IRS grants late-election relief for a tax-exempt controlled entity
The IRS granted a corporation's request for more time to make an election under IRC § 168(h)(6)(F)(ii) to be treated as a taxable entity. The corporation was a tax-exempt controlled entity and…
PLR 1138030: IRS grants 30-day extension to file duplicate Forms 3115
The IRS granted a corporation more time to file duplicate Forms 3115 with the IRS national office after changing its accounting method under Rev. Proc. 2008-52. The taxpayer had timely filed the…
PLR 1138028: 120-day extension to allocate GST exemption to trust transfers
The IRS granted a decedent's estate and the decedent's spouse 120 more days to allocate their generation-skipping transfer tax exemptions to a prior transfer to a trust. The taxpayers' adviser…
PLR 1138012: IRS grants extra time to elect U.S. tax deferral for a Canadian retirement plan
A U.S. resident owned a Canadian Registered Retirement Savings Plan and had not made the election required to defer U.S. tax on income accruing in the plan under Article XVIII(7) of the U.S.-Canada…
PLR 1138011: IRS grants extra time to make a built-in-loss basis election
A business trust and its corporate subsidiary made a transfer intended to qualify under IRC § 351, but they did not timely make the joint election under § 362(e)(2)(C) to allocate built-in losses by…
PLR 1138010: IRS grants extra time for an LLC to elect corporate tax treatment
A limited liability company intended to be treated as an association taxable as a corporation for federal tax purposes but did not timely file Form 8832. The company asked for relief under Treas.…
PLR 1138009: IRS grants extra time for a foreign LLC to elect disregarded-entity status
A foreign eligible entity wholly owned by another entity intended to be treated as a disregarded entity but did not timely file Form 8832. The owner asked for relief under Treas. Reg. § 301.9100-3.…
PLR 1138007: IRS grants extra time to elect out of the section 382(l)(5) limitation
A loss corporation underwent an ownership change while under the jurisdiction of a bankruptcy court. The corporation intended to elect out of the special section 382(l)(5) rules but did not timely…
PLR 1138005: IRS grants extra time for a foreign entity to elect partnership status
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The entity asked for relief under Treas. Reg. § 301.9100-3. The IRS…
PLR 1138004: IRS grants extra time to elect U.S. tax deferral for a Canadian RRSP
A former Canadian resident who became a U.S. resident owned a Canadian Registered Retirement Savings Plan and had not made the election to defer U.S. tax on income accrued in the plan. The taxpayer…
PLR 1138003: IRS grants more time to elect general asset accounts for depreciable property
A parent corporation and four wholly owned subsidiaries asked for more time to elect general asset accounts for depreciable property. The taxpayers had used the general asset account rules when…
PLR 1138001: IRS grants more time to elect the alternative depreciation system
A limited partnership asked for more time to elect the alternative depreciation system for real and personal depreciable property placed in service during a specified taxable year. The taxpayer had…
PLR 1137010: IRS grants more time to elect disregarded-entity treatment
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on a…
PLR 1137009: IRS grants more time to allocate generation-skipping transfer tax exemption
A taxpayer transferred stock to an irrevocable trust for a child and descendants but did not allocate generation-skipping transfer tax exemption on the timely filed gift tax return. The omission…
PLR 1137003: IRS grants more time to elect corporate tax classification
A limited liability company intended to be classified as an association taxable as a corporation for federal tax purposes but did not timely file Form 8832. The company asked for an extension of…
PLR 1137001: IRS grants more time to allocate GST exemption to trust transfers
A taxpayer and spouse made several transfers to an irrevocable trust and consented to split the gifts for gift tax purposes. Their accountant allocated GST exemption to the first two transfers but…
PLR 1136019: IRS grants more time to elect out of additional first-year depreciation
The IRS granted a taxpayer 60 days to make an election not to claim additional first-year depreciation for all classes of qualified property placed in service during a specified tax year. The…
PLR 1136010: Foreign entity granted more time to elect partnership classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the election on time, and the IRS…
PLR 1136006: Taxpayer granted more time to file LIFO elections
A parent corporation asked for more time to file Forms 970 for fourteen subsidiaries that had used the LIFO inventory method but had not timely attached the required election forms. The IRS…
PLR 1136005: Taxpayers granted more time to elect qualified dividend income treatment
A married couple asked for more time to elect to treat qualified dividend income as investment income for purposes of the investment-interest deduction rules. Their tax preparer had failed to advise…
PLR 1136002: Foreign entities granted time to elect partnership classification
Five foreign entities intended to be treated as partnerships for federal tax purposes but failed to timely file Forms 8832. The IRS found that the entities were eligible to make the elections, acted…
PLR 1136001: Foreign entities granted time to elect disregarded-entity status
Three foreign entities intended to be treated as disregarded entities for federal tax purposes but failed to timely file Forms 8832. The IRS found that the entities were eligible to make the…
PLR 1135031: IRS grants late QSub election relief after S status termination
The parent corporation asked the IRS to allow a subsidiary to make a QSub election even though the election date preceded the five-year waiting period that ordinarily follows termination of the…
PLR 1135028: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135027: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135026: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135024: IRS grants late GST exemption allocations after tax-preparer error
A married couple asked the IRS for more time to allocate their generation-skipping transfer tax exemptions to transfers they had made to an irrevocable trust. They intended to make the allocations…
PLR 1135021: IRS grants more time for a partnership to make a late § 754 election
The limited liability company asked for more time to make a § 754 election after a transaction caused a termination under § 708(b)(1)(B). The election would allow adjustments to the basis of…
PLR 1135020: IRS grants extra time for a foreign entity to elect partnership classification
The foreign entity asked the IRS for more time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the classification to apply from an earlier…
PLR 1135018: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135017: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135016: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135015: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135014: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135013: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135012: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for some consenting…
PLR 1135011: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135010: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135009: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135008: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. The company filed Form 973 with its return but omitted Forms 972 for its consenting…
PLR 1135007: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1135006: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1135005: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1135003: IRS grants more time to elect an extended net operating loss carryback
The common parent of a consolidated group asked for more time to elect an extended carryback period for a consolidated net operating loss incurred in a prior year. The group had missed the deadline…
PLR 1134022: IRS grants more time to make a low-income housing credit election
A taxpayer asked for more time to make the § 42(g)(1) election for a low-income housing project. The taxpayer had placed the project in service but inadvertently failed to make a timely, correct…
PLR 1134021: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1134020: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1134019: IRS grants more time for a regulated investment company to make a consent dividend election
A regulated investment company asked for more time to make a consent dividend election for a prior tax year. It filed Form 973 with its return but omitted Forms 972 for its consenting shareholders,…
PLR 1134013: IRS grants late entity-classification election relief
A foreign entity that had been treated consistently as disregarded for federal tax purposes failed to file its entity-classification election on time. The IRS found that the taxpayer acted…
PLR 1134012: IRS grants extra time for a consent dividend election
A regulated investment company failed to attach required shareholder consent forms to its return for a consent dividend election. The IRS found that the taxpayer had acted reasonably and in good…
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.