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 1105018: IRS grants more time for a closing-of-the-books election after an ownership change
A corporation with accumulated net operating losses experienced a second ownership change and failed to make a regulatory election to close its books on the change date. The IRS granted 45…
PLR 1105014: IRS grants a late election to capitalize interest
A partnership that owned unimproved and unproductive real property deducted interest expense instead of electing to capitalize it under IRC § 266. The taxpayer said its preparers failed to identify…
PLR 1105013: IRS grants a late election for corporate bonus depreciation credits
A C corporation had elected not to claim bonus depreciation and had unused alternative minimum tax and research credits from earlier years. It asked for more time to make the related IRC § 168(k)(4)…
PLR 1104029: Agencies received more time to make private-activity-bond carryforward elections
The IRS granted two state agencies an extension of time to file Form 8328 and carry forward unused private activity bond volume cap. The filing was late because the state was coordinating a new…
PLR 1104027: The IRS granted more time to file Form 3115 with an amended return
The IRS granted a partnership-taxed limited liability corporation 60 days to file an original Form 3115 with an amended federal partnership return. The taxpayer had inadvertently failed to file Form…
PLR 1104026: IRS grants a foreign entity more time to elect partnership status
A foreign entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity said it intended to make the election effective when it was…
PLR 1104025: IRS grants more time to make a section 754 election
A partnership asked for more time to make a section 754 election after an inadvertent omission. A related entity had made a distribution in liquidation of a member's interest, and the resulting…
PLR 1104022: IRS grants more time to allocate generation-skipping transfer tax exemption
A donor asked for more time to allocate available generation-skipping transfer tax exemption to five irrevocable trusts created for the donor's children and their descendants. The donor had filed a…
PLR 1104018: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104016: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104015: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104014: IRS grants late entity classification and S corporation election relief
A limited liability company asked for relief after it failed to timely file Form 8832 to elect association classification and Form 2553 to elect S corporation status. The IRS granted 120 days to…
PLR 1104012: IRS grants more time to opt out of automatic GST exemption allocation
A donor asked for more time to elect out of the automatic allocation of generation-skipping transfer tax exemption to transfers made to an irrevocable trust. The donor relied on law and accounting…
PLR 1104011: IRS grants more time to elect association classification
A business entity asked for more time to file Form 8832 and elect to be classified as an association taxable as a corporation for federal tax purposes. The entity intended the election to be…
PLR 1104010: IRS grants a foreign entity more time to elect partnership classification
A foreign entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity failed to file the form by the requested effective date. The IRS…
PLR 1104007: IRS grants more time to elect disregarded entity status
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 was eligible to make the election effective on…
PLR 1104006: IRS grants more time to elect disregarded entity status
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 was eligible to make the election effective on…
PLR 1104002: IRS grants more time to elect partnership classification for a foreign entity
A foreign business entity asked for more time to file an election to be treated as a partnership for federal tax purposes. The entity had failed to timely file Form 8832, even though it intended the…
PLR 1103039: Spouses receive extra time to allocate GST exemptions to family trusts
A married couple asked for more time to allocate their generation-skipping transfer tax exemptions to transfers made to three trusts for their children and grandchildren. Their accountant had failed…
PLR 1103038: Agency receives extra time to correct private-activity-bond volume-cap elections
A state housing-finance agency asked for more time to amend separate Form 8328 elections for regular private-activity-bond volume cap and Housing Act volume cap. State administrative staff had…
PLR 1103037: Parent receives extra time to make a consolidated-return election
A parent company and its wholly owned subsidiary intended to file a consolidated federal income tax return but did not make the election on time. The IRS found that the parent reasonably relied on a…
PLR 1103031: Taxpayer receives 60 more days to elect out of additional first-year depreciation
A limited partnership asked for more time to make the election not to deduct additional first-year depreciation for all classes of qualified property placed in service during a tax year. The…
PLR 1103030: Parent receives more time to make a QSub election for a wholly owned subsidiary
An S corporation parent asked for more time to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary. The parent had contributed the subsidiary’s stock to itself but…
PLR 1103029: Partnership receives more time to make a section 754 election
A limited liability company asked for more time to make a section 754 election after experiencing a technical termination under section 708(b)(1)(B). The entity had inadvertently failed to make a…
PLR 1103027: Affiliated group receives more time to file a consolidated return election
A parent company asked for more time for itself and its subsidiaries to elect to file a consolidated federal income tax return. The election had not been filed by the regulatory deadline, and the…
PLR 1103025: Taxpayer may make a late election related to rehabilitation tax credits
A tax-exempt organization's wholly owned subsidiary, which served as a general partner in two partnerships developing a historic property, asked for more time to make an election under section…
PLR 1103024: Taxpayers may make a late allocation of generation-skipping transfer tax exemptions
A married couple transferred cash to an irrevocable trust for their daughter and her descendants but did not timely allocate their generation-skipping transfer tax exemptions to the transfer. Their…
PLR 1103023: Husband and wife may make late allocations of GST exemptions
A married couple transferred cash to an irrevocable trust for their daughter and her descendants but did not timely allocate their generation-skipping transfer tax exemptions to the transfer. Their…
PLR 1103021: Company may make a late QSub election for its wholly owned subsidiary
An S corporation intended to treat its wholly owned subsidiary as a qualified subchapter S subsidiary, but it did not timely file the required election. The IRS concluded that the requirements for…
PLR 1103016: Taxpayers may make late formula allocations of GST exemption to trust transfers
A donor and spouse transferred stock and a partnership interest to an irrevocable trust, but their tax preparer did not allocate their available generation-skipping transfer tax exemptions to the…
PLR 1103013: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. The IRS concluded that the…
PLR 1103012: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. The IRS concluded that the…
PLR 1103011: Partnership receives more time to make a late section 754 election
A limited partnership failed to make a timely section 754 election after a transfer of a partnership interest because its tax adviser inadvertently missed the election. The IRS concluded that the…
PLR 1103004: Estate receives more time to make a QDOT election
An estate of a noncitizen decedent left property in trust for a surviving noncitizen spouse and claimed the estate tax marital deduction. The estate's accountant failed to make the required…
PLR 1103003: Estate receives more time to make the alternate valuation election
An estate's executor filed the estate tax return without making the alternate valuation election because the accountant who began preparing the return died before it was completed. The executor…
PLR 1102070: Taxpayers receive more time to recharacterize Roth IRA conversions
A married couple converted traditional IRA funds to Roth IRAs but later learned that their modified adjusted gross income exceeded the limit for Roth IRA conversions. They asked for additional time…
PLR 1102054: IRS grants more time to elect disregarded-entity treatment
A foreign entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election but missed the filing…
PLR 1102053: IRS grants more time to allocate a deceased spouse’s GST exemption
A grantor and spouse made gifts to an irrevocable trust and elected to treat the gifts as made one-half by each spouse. Their accounting firm prepared the gift tax returns but failed to allocate the…
PLR 1102041: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102040: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102039: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102038: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102037: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102036: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102035: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102032: IRS grants extensions for entity classification and S corporation elections
The limited liability company intended to be treated as an association taxable as a corporation and as an S corporation, but it failed to timely file Forms 8832 and 2553. The IRS granted the company…
PLR 1102031: IRS grants more time to make an investment-income election
The taxpayers had investment interest expense and net capital gains, but their accountant did not make the election under IRC § 163(d)(4)(B) to treat part of the net capital gain as investment…
PLR 1102026: IRS grants a partnership more time to make a section 754 election
A limited partnership asked for extra time to make a section 754 election after a partner died and the partnership missed the filing deadline. The IRS granted an extension of 120 days from the date…
PLR 1102025: IRS grants an LLC more time to make a section 754 election
A limited liability company treated as a partnership for federal tax purposes asked for extra time to make a section 754 election after a partner died and the company missed the filing deadline. The…
PLR 1102002: IRS grants more time to file a disregarded-entity election
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS granted the entity an additional 120 days from the ruling date to…
PLR 1102001: IRS grants more time to file a disregarded-entity election
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS granted the entity an additional 120 days from the ruling date to…
CCA 1052007: The automatic extension rule may apply to missed estate tax elections
Chief Counsel Advice considered the extension rules for elections under IRC §§ 2032(d) and 2056A(d). It states that Treas. Reg. § 301.9100-2(b) applies when the taxpayer timely filed Form 706,…
PLR 1051022: IRS grants extra time to waive a consolidated NOL carryback
A consolidated corporate group failed to timely file an election to relinquish the entire carryback period for a consolidated net operating loss. The group requested relief under the regulatory…
PLR 1051018: Taxpayer granted more time to make an RRSP election
A Canadian citizen who became a United States resident did not know that a Form 8891 election was needed to defer U.S. tax on income accrued in Canadian RRSP accounts. The taxpayer asked for more…
PLR 1051013: Late disregarded-entity election granted extra time
A foreign entity with one owner intended to be treated as a disregarded entity for U.S. federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief under…
PLR 1051007: Late entity-classification and S corporation elections allowed
An LLC intended to be treated as an S corporation but failed to timely file its entity-classification and S corporation election forms. The IRS granted the LLC 120 days to file Form 8832 and treat…
PLR 1051005: Extension granted to file duplicate Form 3115
A taxpayer timely filed its federal income tax return and original Form 3115 to change an accounting method, but its signed duplicate Form 3115 reached the accounting firm too late to be filed with…
PLR 1051001: Extension granted to file duplicate Form 3115
A taxpayer timely filed its federal income tax return and original Form 3115 to change an accounting method for personal property taxes, but its signed duplicate Form 3115 reached the accounting…
PLR 1050026: Extension granted for a late section 338 election
The IRS granted a purchaser additional time to file a section 338(g) election after the statutory deadline had passed. The purchaser showed that it acted reasonably and in good faith, and the IRS…
PLR 1050023: Extension granted for a rental real estate activity election
The IRS granted married taxpayers additional time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were eligible to make the election…
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.