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 1126013: Married taxpayers received more time to make Canadian RRSP elections
Two taxpayers who had moved from Canada to the United States asked for more time to elect under Rev. Proc. 2002-23 to defer U.S. tax on income accrued in their Canadian Registered Retirement Savings…
PLR 1126008: Donors received more time to elect out of GST exemption allocation
Two spouses asked for more time to elect out of the generation-skipping transfer tax exemption’s automatic allocation rules for transfers to an irrevocable trust. The trust’s drafter had not…
PLR 1126001: Late homeowners-association elections allowed for prior tax years
A homeowners association failed to file income tax returns or make the required elections for several tax years because its officers did not know about the filing requirements. The IRS determined…
CCA 1125020: The cited election-extension regulations did not apply
Chief Counsel Advice addressed whether regulations under § 301.9100 could extend the time for an election. It stated that § 301.9100-2 can extend statutory and regulatory elections when it applies,…
CCA 1125019: Installment elections may qualify for general § 9100 relief
Chief Counsel Advice addressed whether a taxpayer’s attempted election qualified for the automatic six-month extension under § 301.9100-2(b). The advice concluded that the taxpayer had not filed the…
PLR 1125016: Taxpayer and spouse received 120 days to allocate GST exemption
The IRS granted a taxpayer and spouse 120 days to allocate their available generation-skipping transfer tax exemption to gifts made to three child trusts. The IRS also granted the taxpayer 120 days…
PLR 1125014: Consolidated group received 60 days to make an extended NOL carryback election
The IRS granted a consolidated corporate group 60 days to make a late election for an extended net operating loss carryback period. The election concerned a consolidated net operating loss incurred…
PLR 1125002: More time granted to make a rental real estate activity election
The IRS granted a taxpayer 120 more days to elect to treat all interests in rental real estate as a single rental real estate activity. The taxpayer was eligible to make the election but filed its…
PLR 1124016: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124015: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124014: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124013: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124012: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124011: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124010: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124009: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124006: IRS grants late GST exemption allocation relief
The IRS granted a married couple 120 additional days to allocate their available generation-skipping transfer tax exemptions to transfers made to an irrevocable trust. The couple had timely filed…
PLR 1124003: IRS grants late election-out relief for GST exemption allocation
The IRS granted spouses 120 additional days to elect out of the automatic allocation of generation-skipping transfer tax exemption to transfers made to an irrevocable trust. The trust instrument did…
PLR 1124001: IRS grants relief for late taxable REIT subsidiary elections
The IRS granted several REIT-related companies and a subsidiary an extension of time to make elections treating the subsidiary as a taxable REIT subsidiary. The elections were not timely filed…
PLR 1123026: IRS grants a consolidated group extra time to elect an extended NOL carryback
A corporation serving as the common parent of a consolidated group failed to timely file an election for an extended carryback period for a consolidated net operating loss. The IRS granted the group…
PLR 1123024: IRS grants more time for Canada treaty elections on foreign retirement plans
Two people who became U.S. residents after living in Canada had not made the elections required to defer U.S. tax on income accrued in their Canadian RRSPs and a DPSP. The IRS granted them 60 days…
PLR 1123020: IRS grants more time to file a loss election for subsidiary stock
A consolidated corporate group asked for more time to file a regulatory election concerning a loss recognized on the disposition of subsidiary stock. The election statement was required under the…
PLR 1123019: IRS grants more time to file a loss election for subsidiary stock
A consolidated corporate group asked for more time to file a regulatory election concerning a loss recognized on the disposition of subsidiary stock. The election statement was required under the…
PLR 1123018: IRS grants more time to file a loss election for stock sold to an unrelated buyer
A consolidated corporate group asked for more time to file a regulatory election concerning a loss from selling subsidiary stock to an unrelated buyer. The election statement was required under the…
PLR 1123017: IRS grants more time to file a loss election for stock sold to an unrelated buyer
A consolidated corporate group asked for more time to file a regulatory election concerning a loss from selling subsidiary stock to an unrelated buyer. The election statement was required under the…
PLR 1123015: IRS extends the time to make consent dividend elections
An investment corporation asked for more time to make consent dividend elections for a tax year in which its consolidated group had personal holding company income and tax. The corporation said its…
PLR 1123007: IRS grants more time to elect out of automatic GST exemption allocation
A taxpayer created a grantor retained annuity trust before 2001 and later discovered that GST exemption had been automatically allocated when the trust’s estate tax inclusion period closed. The…
PLR 1123006: IRS grants more time to elect corporate tax classification
A foreign entity asked for more time to file Form 8832 to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to be treated as a partnership but…
PLR 1123002: IRS grants more time to elect association tax treatment
An entity asked for more time to file Form 8832 to be classified as an association taxable as a corporation for federal tax purposes. It had intended to make the election effective on its formation…
PLR 1122033: IRS grants late relief to recharacterize a Roth IRA conversion
An individual instructed a financial institution to convert part of a traditional IRA to a Roth IRA, but did not learn that the conversion had occurred until after the deadline for changing it. The…
PLR 1122015: IRS grants more time for a partnership basis election
The IRS granted a partnership an extension of time to make an election under IRC § 754. The partnership had timely filed its return, but the election to adjust the basis of partnership property was…
PLR 1122011: IRS grants an extension for a late section 754 election
The IRS granted a limited liability company treated as a partnership an extension of time to make an election under IRC § 754. The company's return was filed without the election after a member…
PLR 1122010: IRS grants late entity-classification elections for foreign entities
The IRS granted two foreign entities 120 days to file Form 8832 elections to be treated as associations taxable as corporations for federal tax purposes. The entities were eligible to make the…
PLR 1122009: IRS grants an estate more time to elect alternate valuation
An estate timely filed its federal estate tax return, but its executor's first tax professional did not make the alternate valuation election under IRC § 2032. A second tax professional later…
PLR 1121014: extension granted for a consolidated NOL carryback election
The IRS granted a consolidated corporate group an additional 60 days to make an election for an extended net operating loss carryback period. The group missed the original deadline after reasonably…
PLR 1121006: taxpayer permitted to revoke investment-income election
The IRS permitted a taxpayer to revoke an election that treated qualified dividend income and net capital gain as investment income for purposes of the investment interest deduction. The taxpayer…
PLR 1121003: estate granted more time to make a QTIP election
The IRS granted an estate 120 additional days to make a qualified terminable interest property election for a trust benefiting the surviving spouse. The executor's attorney had mistakenly listed the…
PLR 1120018: IRS grants more time for a consolidated NOL carryback election
The IRS granted a consolidated corporate group 60 days from the date of the ruling to file an election for an extended carryback period for a consolidated net operating loss. The group had missed…
PLR 1120016: IRS grants relief for a late Form 1128
The IRS ruled that a taxpayer's late-filed Form 1128 application to change its annual accounting period would be treated as timely filed. The taxpayer intended to make the change on time but missed…
PLR 1120010: late election for a rehabilitation credit treated as timely
The IRS granted a taxpayer 120 days to make a late election treating a tenant as having purchased property for purposes of passing through a rehabilitation credit. The taxpayer had agreed to make…
PLR 1119023: consolidated group may file a late statement for a subsidiary stock loss
A parent corporation asked for more time to file a regulatory statement needed to claim some or all of a loss on the disposition of a subsidiary's stock. The IRS found that the parent acted…
PLR 1119021: regulated investment company may make a late dividends-paid election
A regulated investment company asked for more time to make an election under IRC § 855(a) concerning dividends treated as distributed in an earlier taxable year. Its tax preparer prepared, but did…
PLR 1119020: partnership may make a late section 754 election
A partnership asked for more time to make an IRC § 754 election after filing its return without the election. The election would allow basis adjustments for certain partnership distributions and…
PLR 1119019: foreign entity may make a late election to be treated as a corporation
A foreign entity that had been treated as a partnership asked for more time to elect classification as an association taxable as a corporation after a change in ownership. The entity had been…
PLR 1119015: IRS grants time to make a tax-exempt entity election
A tax-exempt entity that owned part of a partnership holding a historic building asked for more time to elect not to be treated as a tax-exempt entity for a depreciation rule. The taxpayer intended…
PLR 1119012: Foreign entities granted time to elect disregarded-entity status
Eleven foreign entities asked for more time to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities were eligible to make the elections but had not…
PLR 1119010: IRS grants time to make a section 953(d) election
A foreign insurance company asked for more time to elect treatment as a domestic corporation for U.S. tax purposes under IRC § 953(d). The company missed the election deadline because its accountant…
PLR 1119009: IRS grants time for entity-classification and S corporation elections
A limited liability company intended to be treated as an S corporation but missed both the entity-classification and S corporation election deadlines. The IRS granted 120 days to file Form 8832 and…
PLR 1118013: IRS grants extra time for a protective alternate valuation election
The IRS considered an estate that filed its federal estate tax return without a protective alternate valuation election under section 2032. The estate later filed a supplemental return making the…
PLR 1118010: IRS grants extra time to make an IC-DISC election
The IRS considered a domestic corporation that intended to be treated as an interest charge domestic international sales corporation, or IC-DISC, from its first taxable year. The corporation did not…
PLR 1118006: IRS grants more time to allocate GST exemption to prior trust gifts
The IRS considered an estate whose decedent had made gifts to a trust but had not allocated the decedent's generation-skipping transfer tax exemption to gifts made in four earlier years. The…
PLR 1118002: IRS grants more time to elect an extended NOL carryback
The IRS considered the common parent of a consolidated group that missed the deadline to elect an extended carryback period for a consolidated net operating loss. The parent had reasonably relied on…
PLR 1118001: IRS grants more time for taxable REIT subsidiary elections
The IRS considered two real estate investment trusts and their jointly owned subsidiary, which was intended to be treated as a taxable REIT subsidiary of both REITs. The parties filed one Form 8875…
PLR 1117037: IRS grants late recharacterization relief after a tax preparer discovers Roth IRA errors
The IRS considered a married couple whose income exceeded the limits for a Roth IRA conversion and some regular Roth IRA contributions. Their CPA discovered the problem only after the deadline for…
PLR 1117025: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
PLR 1117024: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
PLR 1117023: Consolidated group received more time to elect an extended NOL carryback
The IRS granted a consolidated corporate group an extension of time to elect an extended carryback period for a net operating loss. The group had filed Form 1139 but had not made a valid…
PLR 1117022: Acquiring consolidated group received more time to waive a prior-group NOL carryback
The IRS granted an acquiring consolidated group 45 days from the ruling date to make an election waiving the portion of the net operating loss carryback period attributable to subsidiaries’…
PLR 1117019: IRS allows more time to request revised nuclear decommissioning fund ruling amounts
The taxpayer owned an interest in a nuclear power plant and had received a schedule of ruling amounts for its qualified decommissioning fund. After the Nuclear Regulatory Commission extended the…
PLR 1117018: IRS grants late-election relief for foreign entity classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make that…
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.