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 1117011: Extension of time to elect single rental real estate activity
The IRS considered a taxpayer's request to treat all interests in rental real estate as one activity for passive activity purposes. The taxpayer qualified for the real property business exception…
PLR 1117003: Extension for a late disregarded-entity election
The IRS considered a foreign eligible entity that intended to be treated as disregarded for federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief…
PLR 1116013: IRS granted time to correct consent-dividend elections
The IRS considered a parent company and two real estate investment trust subsidiaries that had reported incorrect amounts for consent dividends because of clerical, transcription, coding, sorting,…
PLR 1116012: IRS accepted a late Form 1128 for an accounting-period change
The IRS considered a taxpayer that filed Form 1128 late to change its federal income tax accounting period from a year ending August 31 to a year ending December 31. The taxpayer had filed the…
PLR 1116011: IRS allowed an LLC to change to disregarded-entity status
The IRS considered an eligible limited liability company that had elected to be treated as an association taxable as a corporation. The taxpayer represented that more than 50 percent of the…
PLR 1116010: IRS granted time to make a section 754 election
The IRS considered a partnership that failed to timely make a section 754 election after one partner sold an interest to another person. The partnership represented that it relied on tax advisers,…
PLR 1116004: IRS granted time for reverse QTIP and GST elections
The IRS considered an estate that had reported a marital trust as QTIP property but had not separately identified its GST-exempt and GST-nonexempt portions, made a reverse QTIP election, or…
PLR 1115028: IRS allowed a surviving spouse to roll over inherited IRA funds
The IRS considered a surviving spouse who received a deceased spouse’s IRA through a trust and then took a one-time distribution based on advice from a financial professional. The trust gave the…
IRS grants extra time to waive the carryback period for consolidated net operating losses
The parent of a consolidated corporate group asked for more time to file an election waiving the entire carryback period for the group’s consolidated net operating losses. The IRS concluded that the…
IRS grants extra time to identify all buildings in a low-income housing project
The IRS granted a taxpayer 120 additional days to elect to treat all buildings in a multi-building project as one project for purposes of the low-income housing credit. The taxpayer had…
IRS grants extra time to elect IC-DISC status
The IRS granted a domestic corporation 60 additional days to file Form 4876-A, the election to be treated as an interest charge domestic international sales corporation. The corporation intended to…
IRS grants extra time for a partnership’s section 754 election
The IRS granted a partnership 120 additional days to make a section 754 election. The partnership had resulted from a merger and later admitted new investors, but it inadvertently failed to make the…
IRS grants time to recharacterize a failed Roth IRA conversion
The IRS granted an individual up to 60 days to recharacterize a failed conversion from a traditional IRA to a Roth IRA. The taxpayer relied on a CPA’s advice that modified adjusted gross income…
PLR 1114018: IRS grants an extension to make an insurance company election
The IRS granted a property and casualty insurance company 60 days from the ruling date to make an election to be taxed under IRC § 831(b)(2)(A). The company had intended to make the election but did…
PLR 1114014: IRS grants 75 days to file consolidated-return loss elections
The IRS granted a consolidated group 75 days to file elections related to a worthless stock loss for a subsidiary. The parent had claimed the loss on an amended return but had not timely filed the…
PLR 1114013: IRS grants 75 days to file consolidated-return loss elections
The IRS granted a consolidated group 75 days to file elections related to a worthless stock loss for a subsidiary. The parent had claimed the loss on an amended return but had not timely filed the…
PLR 1114012: IRS grants 120 days to make a late entity-classification election
The IRS granted an entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested earlier date. The entity had failed to file…
PLR 1114011: IRS grants 120 days to make a late section 754 election
The IRS granted a limited liability company 120 days to make a late election under IRC § 754 for the tax year in which a member died. The company had inadvertently missed the deadline for the…
PLR 1114008: IRS grants 120 days to make low-income housing elections
The IRS granted a taxpayer 120 days to make elections for a low-income housing project under IRC §§ 42(g)(1) and 142(d)(4)(B). The taxpayer had intended to make the elections and had filed its…
PLR 1114007: IRS grants 30 days to file a duplicate Form 3115
The IRS granted a taxpayer 30 days to file a signed duplicate Form 3115 after the taxpayer's preparer failed to submit it on time. The form related to a change in inventory valuation from cost to…
PLR 1114002: IRS permits an ESBT revocation and late QSST election
The IRS allowed a trust that owned shares of an S corporation to revoke its electing small business trust status as of a specified date. The IRS also granted the trust 120 days to make a qualified…
PLR 1113026: IRS grants extra time for a taxable REIT subsidiary election
A real estate investment trust and an indirectly owned subsidiary intended to elect taxable REIT subsidiary status under IRC § 856(l), but the election was not timely filed. The taxpayers…
PLR 1113022: extension granted to waive a consolidated net operating loss carryback
The IRS granted a consolidated group additional time to elect to relinquish the entire carryback period for a consolidated net operating loss. The parent intended to make the election but did not…
PLR 1113016: IRS grants extra time to file an election for a consolidated group's subsidiary stock loss
The IRS granted a consolidated corporate group 60 additional days to file a statement election related to a claimed loss on stock of a wholly owned subsidiary that had become worthless. The group…
PLR 1113013: IRS grants late entity classification elections for six foreign entities
The IRS gave six foreign entities 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities had not timely filed valid elections but had…
PLR 1113011: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity was eligible to make the election but had not filed the form after…
PLR 1113010: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had not filed the election after receiving inadequate advice about…
PLR 1113009: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had not filed the election after receiving inadequate advice about…
PLR 1113008: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had not filed the election after receiving inadequate advice about…
PLR 1113007: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had not filed the election after receiving inadequate advice about…
PLR 1113006: IRS grants extra time to elect disregarded-entity status
The IRS gave a foreign entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity's current owner had acquired it, but the entity had not…
PLR 1113005: IRS grants extra time to elect partnership classification
The IRS gave a foreign entity 120 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had not filed the election after receiving inadequate advice about…
PLR 1112005: Taxpayer received more time to make an IC-DISC election
A domestic corporation asked for more time to file Form 4876-A and shareholder consents so it could be treated as an interest charge domestic international sales corporation, or IC-DISC, for its…
PLR 1112003: foreign entity receives more time to elect partnership classification
The IRS granted a foreign eligible entity 120 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to make the election on time…
PLR 1112002: liquidating trust receives more time to make disputed ownership fund election
The IRS granted a reserve established by a liquidating trust 45 more days to file the statement needed to elect disputed ownership fund treatment. The reserve's trustee had not timely filed the…
PLR 1110010: IRS grants late election relief for a foreign entity to be treated as disregarded
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 was wholly owned by another…
PLR 1110005: IRS grants late GST exemption allocation relief for fifteen trusts
The IRS granted an estate 120 days to allocate the decedent's generation-skipping transfer tax exemption to transfers made to fifteen irrevocable trusts. The decedent's accounting firm had failed to…
PLR 1110004: IRS grants spouses additional time to allocate GST exemptions to five trust transfers
The IRS granted Donor and Spouse 120 days to allocate their respective generation-skipping transfer tax exemptions to transfers made to five irrevocable trusts. Their accountant had reported the…
PLR 1110002: IRS permits a late election to treat more net capital gain as investment income
The IRS allowed a married couple to revoke their original election and make a late election to treat additional net capital gain as investment income. The couple had made the election on Form 4952…
PLR 1109016: The IRS granted more time for a reverse QTIP election and GST exemption allocation
An estate asked for more time to make a reverse qualified terminable interest property (QTIP) election and allocate the decedent's generation-skipping transfer tax exemption to two trusts. The…
PLR 1109014: The IRS granted more time to make an alternate valuation election
An estate asked for more time to make the alternate valuation election under IRC § 2032. The IRS had previously issued a ruling to the estate, then reconsidered the matter and concluded that the…
PLR 1109012: The IRS retroactively revoked an extension for an inter vivos QTIP election
The IRS had previously granted an extension of time to make an inter vivos QTIP election for a transfer of stock to a trust for a spouse. The IRS later concluded that the prior ruling was incorrect…
PLR 1109010: The IRS granted more time to allocate GST exemption to four trusts
An individual asked for more time to allocate generation-skipping transfer (GST) tax exemption to transfers made to four trusts for the benefit of children and their descendants. The individual had…
PLR 1109009: The IRS granted an estate more time to allocate GST exemption to four trusts
The executor of an estate asked for more time to allocate the decedent's generation-skipping transfer (GST) tax exemption to transfers made to four trusts for the benefit of children and their…
PLR 1109008: The IRS granted a liquidating trust more time to elect disputed ownership fund treatment
A reserve within a bankruptcy liquidating trust asked for more time to elect treatment as a disputed ownership fund under Treas. Reg. § 1.468B-9(c)(2)(ii). The election had to be attached to the…
PLR 1109007: The IRS granted a liquidating trust more time to elect disputed ownership fund treatment
A reserve within a bankruptcy liquidating trust asked for more time to elect treatment as a disputed ownership fund under Treas. Reg. § 1.468B-9(c)(2)(ii). The election had to be attached to the…
PLR 1109005: The IRS granted more time to allocate GST exemptions to trust transfers
Grantor and Spouse asked for more time to allocate their generation-skipping transfer tax exemptions to transfers made to an irrevocable trust. Their accountant and tax preparer failed to make the…
PLR 1108027: Taxpayer granted more time to elect single rental real estate activity treatment
The IRS granted a taxpayer an extension of time to elect to treat all interests in rental real estate as one rental real estate activity. The taxpayer was in a real property business and qualified…
PLR 1108023: Partnership granted more time to make a section 754 election
The IRS granted a partnership an extension of time to make a section 754 election. The partnership had timely filed its return but failed to include the election, which can allow basis adjustments…
PLR 1108019: Foreign entity granted more time to elect partnership classification
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity was eligible to make the election but had…
PLR 1108014: Taxpayer receives more time to elect out of bonus depreciation
A corporation discovered that it had omitted election statements from several timely filed tax returns. The statements were needed to elect not to deduct additional first-year depreciation for…
PLR 1108013: Late IC-DISC election receives an extension
A domestic corporation intended to be treated as an interest charge domestic international sales corporation, or IC-DISC, from its formation. Its representative failed to file Form 4876-A within the…
PLR 1108011: Affiliated companies receive more time to elect out of bonus depreciation
An affiliated group and two partnership subsidiaries omitted election statements from their timely filed returns. The statements were needed to elect not to deduct additional first-year depreciation…
PLR 1108010: Family receives more time to allocate GST tax exemptions
A donor and spouse failed to allocate their generation-skipping transfer tax exemptions to transfers made to a trust. The failure occurred when their accountant did not prepare the required…
PLR 1108007: Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded for federal tax purposes but failed to timely file Form 8832. The IRS concluded that the requirements for late-election relief were…
PLR 1108006: Partnership receives more time to make a section 754 election
A partnership failed to timely make a section 754 election after a new owner acquired an interest in the partnership. The partnership said it relied on its tax adviser, acted reasonably and in good…
PLR 1108005: Spouses receive more time to allocate GST exemptions
A husband and wife created and funded a trust but their law firm failed to report the transfers on their gift tax returns and did not allocate their generation-skipping transfer tax exemptions. The…
PLR 1108002: Spouses receive more time to allocate GST exemptions to a trust
A husband and wife transferred interests in a limited partnership to a trust but their tax adviser failed to allocate their generation-skipping transfer tax exemptions on their gift tax returns. The…
PLR 1105029: Taxpayer receives more time to make a tax-exempt controlled entity election
The IRS considered a for-profit corporation owned by a tax-exempt organization that had missed the deadline for an election under § 168(h)(6)(F)(ii). The corporation said the missed deadline…
PLR 1105020: IRS grants more time to make an insurance-company tax election
An affiliated group's captive insurance company asked for more time to elect the alternative tax under IRC § 831(b). The group said its accounting firm incorrectly compared total earned premiums…
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.