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 1041023: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041022: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041021: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041020: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041019: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041018: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041017: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041016: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041015: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041014: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041013: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041012: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041011: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041010: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041009: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041008: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041007: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 1041006: The IRS granted more time for split-dollar loan representations
The IRS granted a subsidiary up to 30 days to prepare and sign written representations concerning nonrecourse split-dollar life insurance loans made to employee participants. The representations…
PLR 1039023: IRS granted extra time to elect disregarded-entity status
The IRS granted a foreign single-owner 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 that…
PLR 1039021: IRS granted more time to elect taxable REIT subsidiary status
Two companies asked the IRS for more time to jointly elect to treat a wholly owned subsidiary as a taxable REIT subsidiary. Their advisers and lawyers each believed the other party was responsible…
PLR 1039015: IRS granted more time to elect out of GO Zone depreciation
A partnership had timely filed its tax return but accidentally omitted the statement needed to elect out of the Gulf Opportunity Zone additional first-year depreciation deduction. The IRS granted…
PLR 1039007: IRS granted more time to file a consolidated return election
An affiliated group asked for more time to make a regulatory election to file a consolidated federal income tax return for a prior tax year. The IRS found that the group reasonably relied on a…
PLR 1039006: IRS granted 60 days to submit a duplicate accounting-method form
An S corporation asked for more time to file a signed duplicate copy of Form 3115 with the IRS national office after changing an accounting method for depreciable property of its qualified…
PLR 1039004: IRS extended time to allocate generation-skipping transfer tax exemption
An estate asked for more time to allocate the decedent's available generation-skipping transfer tax exemption to a family trust. The estate's accountant had mistakenly allocated exemption to a…
PLR 1038011: IRS granted more time to file an election relinquishing a consolidated loss carryback
A corporate group failed to timely file an election to relinquish the carryback period for a consolidated net operating loss. The taxpayer said it relied on a qualified tax professional and…
PLR 1038009: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted a 120-day extension to make the election…
PLR 1038007: IRS granted more time to file a duplicate Form 3115
A taxpayer timely filed an original Form 3115 to change its accounting method for internally developed computer software but inadvertently failed to file the required duplicate with the IRS national…
PLR 1038003: IRS granted late-election relief for disregarded-entity status
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but failed to timely file Form 8832. The IRS granted an extension of 120 days from the ruling date to make…
PLR 1038002: IRS granted late-election relief for partnership status
A foreign entity intended to be treated as a partnership for federal tax purposes but failed to timely file Form 8832. The IRS granted an extension of 120 days from the ruling date to make the…
PLR 1037022: IRS granted more time for a disregarded-entity election
The IRS granted a 120-day extension for a foreign single-member limited liability company to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The company’s parent had…
PLR 1037021: IRS granted relief for a late foreign-insurance-company election
The IRS granted a foreign insurance company a 60-day extension to make an election under IRC § 953(d) to be treated as a domestic corporation for U.S. tax purposes. The company intended to make the…
PLR 1037018: IRS granted late-election relief to a foreign insurer
The IRS granted a foreign property-and-casualty insurance company 60-day extensions to make elections under IRC § 953(d) to be treated as a domestic corporation and under § 831(b) to use the…
PLR 1037013: IRS granted more time for a section 338(h)(10) election
The IRS granted Purchaser and Sellers an extension of time to file a joint section 338(h)(10) election for Purchaser's acquisition of an S corporation. The election was not filed by the due date,…
PLR 1037011: IRS granted late disregarded-entity election relief to three foreign entities
The IRS granted three related foreign entities 120-day extensions to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities represented that they had…
PLR 1037010: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it had been eligible for that…
PLR 1037009: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it had been eligible for that…
PLR 1037008: IRS granted late partnership elections to three foreign entities
The IRS granted three related foreign entities 120-day extensions to file Form 8832 elections to be treated as partnerships for federal tax purposes. The entities represented that they were eligible…
PLR 1037003: IRS granted late disregarded-entity election relief to a foreign entity
The IRS granted a foreign entity a 120-day extension to file Form 8832 and elect disregarded-entity treatment for federal tax purposes. The entity represented that it was eligible for that…
PLR 1037002: IRS granted late GST exemption allocation relief
The IRS granted an executor a 120-day extension to allocate the decedent's generation-skipping transfer tax exemption to a trust. The executor's tax professional timely filed the estate tax return…
CCA 1036019: Late entity-classification relief under Revenue Procedure 2009-41
Chief Counsel advice addressed how a service center should process a request under Revenue Procedure 2009-41 when the requested effective date for an entity-classification election is more than…
PLR 1036011: 120-day extension granted for GST exemption allocation
The IRS granted a surviving spouse an additional 120 days to allocate available generation-skipping transfer tax exemption to transfers made to two trusts. The spouses had consented to split the…
PLR 1036010: 120-day extension granted for GST exemption allocation
The IRS granted a taxpayer an additional 120 days to allocate available generation-skipping transfer tax exemption to transfers made to two trusts. The spouses had consented to split the gifts, but…
PLR 1036003: Late S election and QSub election relief granted
The IRS granted a corporation relief to make a late S corporation election and an additional 60-day extension to elect to treat its wholly owned subsidiary as a qualified subchapter S subsidiary.…
PLR 1035008: IRS granted extra time to allocate generation-skipping transfer tax exemption
The IRS considered a donor who created an irrevocable trust and failed to allocate available generation-skipping transfer tax exemption to later-created trusts for the donor’s children and…
PLR 1035006: IRS granted extra time to make a § 362(e)(2)(C) election
The IRS considered a partnership that was expected to become a corporation through an entity-classification election and would have transferred property with an aggregate basis greater than its fair…
PLR 1035005: IRS granted extra time to make § 338(g) elections
The IRS considered a purchaser and an affiliate that acquired all the stock of a foreign target and its foreign subsidiaries and intended to make § 338(g) elections. The elections were not timely…
PLR 1035002: IRS granted extra time for a consent dividend election
The IRS considered a personal holding company that had paid personal holding company tax after failing to make a consent dividend election for an earlier tax year. The company’s president was…
PLR 1035001: IRS granted extra time to allocate GST exemption to a trust
The IRS considered a taxpayer who created an irrevocable trust, transferred property to it, and failed to report the transfer or allocate generation-skipping transfer tax exemption because an…
PLR 1034013: IRS grants more time to allocate generation-skipping transfer tax exemption
The IRS granted a donor an additional 60 days to allocate available generation-skipping transfer tax (GST) exemption to earlier transfers to four trusts. The donor’s tax professional had failed to…
PLR 1034009: IRS grants more time for spouses to allocate GST exemption
The IRS granted a decedent and spouse an additional 60 days to allocate their generation-skipping transfer tax (GST) exemptions to prior transfers to two trusts. Their accountant had reported the…
PLR 1034008: IRS grants more time for spouses to allocate GST exemption
The IRS granted a decedent and spouse an additional 60 days to allocate their generation-skipping transfer tax (GST) exemptions to prior transfers to two trusts. Their accountant had reported the…
PLR 1034001: IRS permits revocation of a capital-gain investment-income election
The IRS considered taxpayers’ request to revoke an election that treated net capital gains from real property as investment income for purposes of the investment-interest rules. The taxpayers had…
PLR 1033032: Extension granted to make section 59(e) elections
The IRS granted a taxpayer more time to make section 59(e) elections for two redacted taxable years. The taxpayer had not made the elections on time and submitted representations explaining the…
PLR 1033029: Extension granted to make a section 338(g) election
The IRS granted a purchaser 45 days to file a late section 338(g) election for its acquisition of a foreign corporation’s stock. The purchaser represented that the acquisition was a qualified stock…
PLR 1033026: Extension granted for a late investment-income election
The IRS granted a taxpayer 60 days to make a late election to treat net capital gains from investment property as investment income for purposes of the investment-interest deduction. The taxpayer’s…
PLR 1033024: IRS granted extra time to elect partnership classification
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The company intended the election to be effective…
PLR 1033023: IRS denied late-election relief for an estate's alternate valuation election
The IRS denied an estate's request for additional time to make an alternate valuation election under IRC § 2032. The estate's representatives filed the estate tax return on time, but the preparer…
PLR 1033020: IRS granted more time to elect deductions for intangible drilling costs
The IRS granted taxpayers an extension of time to make an election under IRC § 263(c) to deduct intangible drilling and development costs for a specified taxable year. The taxpayers did not make the…
PLR 1033015: IRS granted more time for a rental real estate election
Married taxpayers who filed a joint return were eligible to elect to treat all their rental real estate interests as one rental real estate activity. They filed the return without the statement…
PLR 1033009: IRS granted more time to file a consolidated return election
An acquired corporation and its subsidiaries failed to make a timely election to file a consolidated federal income tax return. The successor parent requested relief after discovering the missed…
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.