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 1050022: 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…
PLR 1050001: IRS grants late-election relief for a foreign entity to be treated as disregarded
The taxpayer was a foreign business entity with one owner and limited liability. It intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS…
PLR 1049023: LLC receives more time to elect corporate and S corporation status
This ruling concerns an LLC that intended to be classified as a corporation and to elect S corporation status, but did not timely file Forms 8832 and 2553. The IRS granted the LLC 120 days from the…
PLR 1049022: Parent receives more time to file a consolidated return election
This ruling concerns a parent corporation and its subsidiary that intended to file a consolidated federal income tax return but did not timely make the election. The IRS granted the parent an…
PLR 1049020: Late Form 1128 is treated as timely filed
This ruling addresses a taxpayer's late Form 1128 seeking to change its federal tax year from a June 30 year-end to a December 31 year-end. The IRS concluded that the taxpayer acted reasonably and…
PLR 1049012: Estate receives more time to allocate GST exemption
This ruling addresses an irrevocable trust funded by a lifetime transfer for which the donor's available generation-skipping transfer tax exemption was not allocated on Form 709. The IRS found that…
PLR 1049004: Taxpayers receive more time to make consent dividend elections
A corporate group asked for more time to make consent dividend elections after discovering that a subsidiary had been a personal holding company for several years. The IRS concluded that the…
PLR 1049001: IRS denies § 9100 relief for late DISC election
A domestic corporation asked for more time to file Form 4876-A to elect interest charge DISC status for an earlier tax year. The IRS determined that the applicable election deadline came from the…
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.