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 1033004: IRS granted relief for late entity classification and S corporation elections
An LLC intended to be classified as a corporation and treated as an S corporation from its formation date, but it did not timely file Form 8832 or Form 2553. The IRS granted the LLC 60 days to file…
PLR 1033003: IRS granted more time for a foreign entity to elect partnership classification
A foreign entity with two members intended to be treated as a partnership for federal tax purposes, but it did not timely file Form 8832. The IRS granted the entity 60 days from the ruling date to…
PLR 1033002: IRS granted more time to elect ADS depreciation
The taxpayer owned and operated a residential rental property with related 5-year and 15-year property. The taxpayer intended to elect the alternative depreciation system, or ADS, but filed its…
PLR 1032024: Estate granted more time to allocate generation-skipping transfer tax exemption
The taxpayer created an irrevocable trust and made transfers to it, but the required gift tax returns did not allocate the taxpayer's generation-skipping transfer tax exemption. No taxable…
PLR 1032022: Trustee granted more time to certify spouse's citizenship for QDOT
An estate elected to treat a trust as a qualified domestic trust for a surviving spouse who was not a U.S. citizen when the decedent died. The spouse later became a U.S. citizen and had continuously…
PLR 1032019: LLC granted extra time to elect corporate tax classification
The taxpayer was a limited liability company that intended to elect classification as a corporation for federal tax purposes but inadvertently failed to file Form 8832. The IRS explained the…
PLR 1032015: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032014: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032013: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032012: IRS granted late-election relief for partnership classification
A foreign eligible entity intended to elect partnership classification for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted…
PLR 1032011: IRS granted late-election relief for disregarded-entity status
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the taxpayer acted reasonably…
PLR 1032008: IRS granted time to correct an incomplete entity election
A foreign eligible entity filed an incomplete Form 8832 when it intended to elect disregarded-entity status for federal tax purposes. The IRS found that the requirements for relief under Treas. Reg.…
PLR 1032007: IRS granted time to file a late entity election
A foreign entity inadvertently failed to timely file Form 8832, Entity Classification Election. The IRS concluded that the requirements for relief under Treas. Reg. § 301.9100-3 were satisfied…
PLR 1032006: IRS granted time to file a late disregarded-entity election
A foreign entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the requirements for relief under…
PLR 1032005: IRS granted time to correct an entity election date
A foreign entity filed Form 8832 but used an incorrect effective date for its disregarded-entity election. The entity represented that it had consistently been treated as disregarded for federal tax…
PLR 1032004: IRS granted time to file a late disregarded-entity election
A foreign entity whose default classification was an association taxable as a corporation intended to elect disregarded-entity status but failed to timely file Form 8832. The IRS concluded that the…
PLR 1032001: IRS granted time to make a late section 754 election
A partnership inadvertently failed to timely make a section 754 election after an ownership interest was acquired. The IRS concluded that the partnership acted reasonably and in good faith and that…
PLR 1031031: IRS granted an extension to elect corporate tax classification for an LLC
The IRS granted a limited liability company an extension of time to file Form 8832 and elect to be classified as an association taxable as a corporation. The LLC had defaulted to partnership status…
PLR 1031029: IRS granted an extension to elect disregarded-entity treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for U.S. income tax purposes. The entity had inadvertently failed to file the…
PLR 1031028: IRS granted an extension to elect partnership treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for U.S. income tax purposes. The entity had inadvertently failed to file the…
PLR 1031027: IRS granted an extension to elect corporate treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a corporation for U.S. income tax purposes. The entity had a single owner without limited liability…
PLR 1031026: IRS granted an extension to elect corporate treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a corporation for U.S. income tax purposes. The entity had a single owner without limited liability…
PLR 1031025: IRS granted an extension to elect corporate treatment for a foreign entity
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a corporation for U.S. income tax purposes. The entity had a single owner without limited liability…
PLR 1031024: IRS granted an extension to elect disregarded-entity treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for U.S. income tax purposes. The entity had inadvertently failed to timely…
PLR 1031023: IRS granted an extension to elect partnership treatment
The IRS granted an entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was organized under foreign law by two owners with…
PLR 1031022: IRS granted an extension to elect disregarded-entity treatment
The IRS granted an entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was organized under foreign law by a single…
PLR 1031021: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031020: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031019: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031018: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031017: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031016: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031015: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031013: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031012: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031011: IRS granted an extension to elect partnership treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was formed under foreign law and represented…
PLR 1031009: IRS granted an extension to group rental real estate interests
The IRS granted married taxpayers an extension of time to elect to treat all of their rental real estate interests as one rental real estate activity. They had filed a joint return without the…
PLR 1031008: IRS granted an extension to group rental real estate interests
The IRS granted a taxpayer an extension of time to elect to treat all rental real estate interests as one rental real estate activity. The taxpayer qualified under the real property business…
PLR 1031006: IRS granted an extension to make a section 754 election
The IRS granted a partnership an extension of time to make a valid IRC § 754 election. The partnership had transferred partnership interests but filed its return without a valid election to adjust…
PLR 1031005: IRS granted an extension to make a section 754 election
The IRS granted a partnership an extension of time to make a valid IRC § 754 election. The partnership had transferred partnership interests but filed its return without a valid election to adjust…
PLR 1031004: IRS granted an extension to elect corporate treatment
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity was formed under…
PLR 1031003: IRS granted more time to make QSub elections
The IRS granted a corporation an extension of time to file Forms 8869 for 24 subsidiaries and elect to treat them as qualified subchapter S subsidiaries. The corporation intended the elections to be…
PLR 1031002: IRS granted more time to make QSub elections
The IRS granted a corporation an extension of time to file Forms 8869 for seven subsidiaries and elect to treat them as qualified subchapter S subsidiaries. The corporation intended the elections to…
PLR 1030023: Extension granted for late Form 3115 filing
The IRS granted a real estate investment trust an extension of time to file Form 3115, which requested a change in its accounting method for depreciable assets. The taxpayer had timely filed a…
PLR 1030003: Extension granted for a section 382 closing-of-the-books election
The IRS granted a consolidated group an extension of time to make a regulatory closing-of-the-books election under section 1.382-6(b). The election concerns how the group allocates income, losses,…
PLR 1029013: IRS grants late-filed accounting-period change relief
A taxpayer asked the IRS to treat a late-filed Form 1128 as timely so it could change its federal tax year. The taxpayer said it intended to file on time but missed the deadline because of an error…
PLR 1029012: IRS grants extra time to elect treatment of investment income
Individual taxpayers asked for more time to elect to treat qualified dividends and certain net capital gain as investment income for purposes of deducting investment interest. Their tax preparer…
PLR 1029008: The IRS granted a foreign entity more time to elect partnership classification
The IRS granted a foreign eligible entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had inadvertently failed to file the…
PLR 1029006: The IRS accepted a late Form 1128 to change the taxpayer’s accounting period
The IRS treated a taxpayer’s late Form 1128 as timely filed for a requested change from a December 31 year-end to a September 30 year-end. The taxpayer had missed the filing deadline for the short…
PLR 1029004: The IRS allowed a late election to combine rental real estate activities
The IRS granted married taxpayers 60 days to make a late election to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were in a real property…
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.