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 1134011: 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…
PLR 1134010: 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…
PLR 1134009: 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…
PLR 1134008: 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…
PLR 1134007: 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…
PLR 1134006: 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…
PLR 1134005: 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…
PLR 1134004: 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…
PLR 1134003: IRS grants more time to elect a current deduction for drilling costs
A privately owned corporation incurred intangible drilling and development costs in its oil and gas business but did not elect to deduct those costs currently on its first relevant tax return. Its…
PLR 1134001: IRS grants more time to waive a consolidated group's loss carryback
A parent company failed to timely file an election to relinquish the entire carryback period for its consolidated group's net operating loss. The IRS found that the parent acted reasonably and in…
PLR 1133009: Taxpayer granted more time to elect deductions for drilling costs
The IRS granted a taxpayer an extension of time to make an election under section 263(c) to deduct intangible drilling and development costs. The taxpayer had not made the election on time and…
PLR 1133008: Parent granted more time to file a consolidated return election
The IRS granted a parent corporation and its affiliated group more time to elect consolidated return treatment after the group failed to file the election by the deadline. The ruling requires the…
PLR 1133005: Late GST exemption allocation granted with transfer-date effect
The IRS granted a taxpayer 120 additional days to allocate generation-skipping transfer tax exemption to an earlier transfer to an irrevocable trust. The taxpayer’s professionals had failed to make…
PLR 1133002: Foreign entity granted more time to elect partnership status
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had failed to make the election by the…
PLR 1133001: Regulated investment company granted more time for consent dividend election
The IRS granted a regulated investment company 60 additional days to complete a consent dividend election for a prior tax year. The company had filed Form 973 but had not attached the required Forms…
PLR 1132019: IRS grants a foreign entity 120 days to elect partnership classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the election by…
PLR 1132015: IRS grants 60 days to make a bonus depreciation election
The IRS granted a consolidated corporate group 60 days to make an election under section 168(k)(4) for a short taxable year. The taxpayer had filed its original return and a statement indicating the…
PLR 1132014: IRS grants 60 days to file an IC-DISC election
The IRS granted a domestic corporation 60 additional days to file Form 4876-A and elect to be treated as an interest charge domestic international sales corporation, or IC-DISC, for its first…
PLR 1132007: Canadian retirement plan election granted a late-filing extension
The IRS granted a Canadian resident who became a U.S. resident more time to elect deferred U.S. tax treatment for income in a Canadian Registered Retirement Savings Plan. The taxpayer missed the…
PLR 1132006: Late commercial revitalization deduction election treated as timely
The IRS granted a partnership more time to make the election for a commercial revitalization deduction tied to a rehabilitated building in a renewal community. The partnership had filed its return…
PLR 1132005: Late charitable deduction election granted to an estate or trust
The IRS granted a trust 120 more days to elect to treat a charitable contribution made in one tax year as paid in the prior tax year. The trustee intended to make the election but failed to do so on…
PLR 1132004: Late entity-classification election granted for a limited liability partnership
The IRS granted a limited liability partnership 120 more days to file Form 8832 and elect partnership treatment for federal tax purposes. The entity intended to make the election effective when it…
PLR 1132003: Extended CNOL carryback election granted 60-day relief
The IRS granted a consolidated corporate group 60 more days to make an election for an extended carryback period for a consolidated net operating loss. The group had missed the election deadline for…
PLR 1132002: Extended CNOL carryback election granted after acquisition
The IRS granted a corporate parent 60 more days to make an election for an extended carryback period for a consolidated net operating loss. The loss arose after the parent acquired another…
PLR 1132001: Late IC-DISC election granted after adviser oversight
The IRS granted a corporation 60 more days to file Form 4876-A and elect IC-DISC status for its first taxable year. The corporation had been formed for that purpose, but its accounting firm missed…
PLR 1131020: IRS granted more time to make elections for Canadian retirement plans
Two taxpayers who moved from Canada to the United States had Canadian Registered Retirement Savings Plans and had not made the election to defer U.S. taxation on accrued income. The IRS found that…
PLR 1131017: IRS granted more time to make an election for Canadian RRSP accounts
A U.S. resident with Canadian Registered Retirement Savings Plan accounts asked for more time to make the election that defers U.S. taxation on income accrued in those accounts. The taxpayer had…
PLR 1131016: IRS granted more time to file a consolidated return election
A new parent company asked for more time to elect to file a consolidated federal income tax return with its subsidiaries after the original affiliated group changed. The IRS found that the parent…
PLR 1131013: IRS granted more time to allocate GST tax exemption to a trust transfer
A donor transferred property to an irrevocable trust for descendants but did not allocate generation-skipping transfer tax exemption to the transfer. The donor and spouse had relied on tax…
PLR 1131012: IRS granted more time to allocate GST tax exemption to a trust transfer
A spouse transferred property to an irrevocable trust for descendants but did not allocate generation-skipping transfer tax exemption to her share of the transfer. The donor and spouse had relied on…
PLR 1131009: IRS granted extra time to waive a consolidated NOL carryback
A parent company intended to elect to relinquish the entire carryback period for a consolidated group's net operating loss but missed the regulatory filing deadline. The IRS found that the parent…
PLR 1131004: IRS granted more time for homeowners association elections
A homeowners association's accounting firm filed Forms 1120 instead of the required Forms 1120-H for two taxable years. After discovering the error, the association requested additional time to…
PLR 1131002: IRS granted more time to elect to treat rental real estate interests as one activity
The taxpayer was in a real property business and qualified to elect to treat all interests in rental real estate as one rental real estate activity. The taxpayer filed a return without the statement…
PLR 1130004: IRS grants more time to make a section 197(f)(9)(B) election
The IRS granted a taxpayer 60 calendar days to make a section 197(f)(9)(B) election for section 197 intangibles involved in a stock sale. The taxpayer had timely made a related section 338(h)(10)…
PLR 1130002: IRS grants more time to elect out of additional first-year depreciation
The IRS granted a partnership 60 calendar days to make an election not to deduct additional first-year depreciation for all classes of qualified property placed in service during a prior taxable…
PLR 1130001: IRS grants more time to file a LIFO inventory election
The IRS granted a taxpayer 30 days to file Form 970 and adopt the LIFO inventory method for inventory transferred in a section 351 transaction. A subsidiary had transferred inventory to a newly…
PLR 1129034: IRS grants more time to make a taxable REIT subsidiary election
A REIT and a related company asked for more time to elect to treat the company as the REIT's taxable REIT subsidiary. An employee of the firm preparing Form 8875 mistakenly listed the partnership…
PLR 1129030: IRS grants more time for a section 754 election
An entity that began as a disregarded limited liability company later became a partnership and then underwent a technical termination under section 708(b)(1)(B). It inadvertently failed to make a…
PLR 1129027: IRS grants more time to allocate GST exemption to trusts
A married couple failed to allocate their generation-skipping transfer tax exemptions to transfers made to two irrevocable trusts. The IRS found that they acted reasonably and in good faith because…
PLR 1129026: Trust granted more time to make a 65-day election
A trust made a distribution during the first 65 days of a tax year and reported it on the prior year's return, but did not timely make the election required under IRC § 663(b). The IRS concluded…
PLR 1129024: Partnership granted more time to make a section 754 election
A limited liability company became a partnership and later underwent a technical termination, but it failed to file a section 754 election with its return. The partnership represented that it relied…
PLR 1129022: Taxpayer granted more time to elect prior-year disaster loss treatment
A married couple's rental properties were damaged by a federally declared disaster. Their accountant missed the deadline to elect to claim the disaster loss on the prior year's return, and the IRS…
PLR 1128016: IRS extends time to allocate generation-skipping transfer tax exemption
An estate asked for more time to allocate the decedent's generation-skipping transfer tax exemption to transfers for grandchildren and to two trusts. The estate had timely filed its estate tax…
PLR 1128009: IRS grants more time for a rental real estate election
A married couple asked for more time to elect to treat all of their rental real estate interests as one rental real estate activity for passive activity purposes. They had qualified for the election…
PLR 1128004: IRS grants extra time to file a consolidated return election
A new affiliated group asked for more time to elect to file a consolidated federal income tax return after a reverse acquisition changed its group structure. The group had not timely filed the…
PLR 1128002: IRS grants extra time to file a duplicate Form 3115
A partnership asked the IRS for more time to file a signed duplicate copy of Form 3115, which it had used to request an automatic change in accounting method for depreciation. The partnership…
PLR 1128001: IRS grants extra time for a consolidated NOL carryback election
A consolidated corporate group asked for more time to elect an extended carryback period for a consolidated net operating loss. The election would allow the group to carry the loss back three, four,…
PLR 1127009: IRS grants more time to allocate generation-skipping transfer tax exemptions
A married couple created an irrevocable trust for their child and more remote descendants but did not file gift tax returns or allocate their generation-skipping transfer tax exemptions to their…
PLR 1127008: IRS grants late-election relief for LLC classification and S corporation status
An LLC asked for relief after it failed to timely file its entity classification election and S corporation election. The IRS granted 120 days to file Form 8832 to elect association treatment for…
PLR 1127003: IRS grants more time to waive a consolidated NOL carryback period
A consolidated corporate group intended to elect to relinquish the entire carryback period for a consolidated net operating loss but failed to file a valid election on time. The IRS found that the…
PLR 1127002: IRS grants more time for an extended consolidated NOL carryback election
A consolidated corporate group failed to timely file an election to carry a net operating loss back for an extended period under IRC § 172(b)(1)(H). The IRS found that the group reasonably relied on…
PLR 1126027: Extension granted to make a late § 338(g) election
The IRS granted a parent company an extension of time to make a § 338(g) election for a subsidiary's acquisition of a foreign target's stock. The election was not filed by its deadline because the…
PLR 1126026: Taxpayers received more time to elect a single rental real estate activity
The IRS granted married taxpayers an extension to make an election treating all of their rental real estate interests as one rental real estate activity. They had filed a joint return without the…
PLR 1126024: LLC received more time to elect partnership classification
The IRS granted a limited liability company an extension to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The company intended to make the election effective…
PLR 1126021: More time granted for a missed R&E expenditure election
The IRS granted a taxpayer more time to make a § 59(e) election to capitalize and deduct ratably certain research and experimentation expenditures incurred by a subsidiary. The taxpayer had prepared…
PLR 1126019: Extension granted for a tax-exempt controlled entity election
The IRS granted a corporation more time to elect not to be treated as a tax-exempt entity for purposes of the depreciation rules in § 168(h)(6). The corporation was owned by tax-exempt organizations…
PLR 1126018: Extension granted for a Canadian RRSP tax deferral election
The IRS granted a U.S. resident and citizen more time to elect under Rev. Proc. 2002-23 to defer U.S. federal income taxation on income accrued in Canadian Registered Retirement Savings Plans. The…
PLR 1126016: Married taxpayers received more time to elect one rental real estate activity
Married taxpayers asked for more time to elect to treat all of their interests in rental real estate as one rental real estate activity. They had qualified to make the election but filed their joint…
PLR 1126015: Taxpayer received more time to file a signed Form 3115
A taxpayer asked for more time to attach a signed original Form 3115 to a timely filed federal income tax return after changing its accounting method for repair and maintenance costs. The taxpayer…
PLR 1126014: Consolidated group received more time to file a signed Form 3115
A parent corporation asked for more time to attach a signed original Form 3115 to a timely filed federal income tax return for members of its consolidated group. The group had filed duplicate copies…
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.