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 1028012: The IRS granted more time to file a foreign entity classification election
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect its federal tax classification. The entity was eligible to make the election effective on a redacted date, but the…
PLR 1028011: The IRS granted more time to elect association status for a foreign entity
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as an association taxable as a corporation. The entity intended the election to be effective on a…
PLR 1028010: The IRS granted a foreign eligible entity more time to elect disregarded-entity treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be effective on…
PLR 1028009: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 1028008: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 1028007: The IRS granted a foreign entity more time to elect partnership treatment
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended the election to be effective on an…
PLR 1028005: The IRS granted more time to waive a consolidated net operating loss carryback
The IRS granted a consolidated group 45 more days to file an election waiving the entire carryback period for a consolidated net operating loss. The group had missed the filing deadline after…
PLR 1028002: The IRS granted more time to elect corporate classification for an LLC
The IRS granted a limited liability company 60 more days to file Form 8832 and elect to be treated as an association taxable as a corporation. The LLC had converted under state law but did not…
PLR 1027044: Foreign entity granted more time to elect disregarded-entity status
The IRS granted a foreign entity an additional 60 days to file Form 8832 and elect to be treated as a disregarded entity for U.S. income-tax purposes. The entity had one owner and was eligible to…
PLR 1027042: S corporation granted more time to elect qualified subchapter S subsidiary status
The IRS granted an S corporation 60 days to file Forms 8869 and make qualified subchapter S subsidiary elections for three subsidiaries. The corporation had intended the elections to be effective on…
PLR 1027040: Spouses granted more time to allocate generation-skipping transfer tax exemptions
The IRS granted spouses 60 days to allocate their generation-skipping transfer tax exemptions to earlier transfers to an irrevocable trust. Their gift tax returns reported the transfers but did not…
PLR 1027039: Entity granted more time to elect corporation status
The IRS granted an eligible entity 60 days to file Form 8832 and elect to be treated as a corporation for U.S. federal tax purposes. The entity had failed to file the election timely, but the IRS…
PLR 1027028: IRS granted a late election to treat rental real estate as one activity
The IRS granted married taxpayers extra time to elect to treat all of their interests in rental real estate as one rental real estate activity. The taxpayers were engaged in a real property business…
PLR 1027027: IRS granted extra time to file evidence of a decedent's mental disability
Trustees asked for more time to file a physician's certification and other evidence concerning a decedent's mental disability for a generation-skipping transfer tax exception. The decedent had…
PLR 1027026: IRS granted extra time to file evidence of a decedent's mental disability
The executor of an estate asked for more time to file a physician's certification and other evidence concerning a decedent's mental disability for a generation-skipping transfer tax exception. The…
PLR 1027024: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity 60 extra days to file Form 8832 and elect to be treated as a disregarded entity for U.S. income tax purposes. The entity had intended the election to be…
PLR 1027023: IRS granted extra time to make a section 168(k)(4) election
The IRS granted a C corporation 60 days to make a late election under section 168(k)(4). That election allows an eligible corporation to forgo bonus depreciation and use the resulting amount to…
PLR 1027021: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity 120 extra days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity had failed to file the election on…
PLR 1027019: IRS granted extra time for a Canadian RRSP tax-deferral election
The IRS granted a U.S. resident 60 days to elect to defer U.S. federal income taxation on income accrued in Canadian Registered Retirement Savings Plans. The taxpayer had not known that an election…
PLR 1027018: IRS granted a late election to treat rental real estate as one activity
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 said they were in a real…
PLR 1027017: IRS granted extra time for a Canadian RRSP tax-deferral election
The IRS granted a U.S. resident 60 days to elect to defer U.S. federal income taxation on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had not known that an election…
PLR 1027016: IRS granted extra time for a Canadian RRSP tax-deferral election
The IRS granted a U.S. resident 60 days to elect to defer U.S. federal income taxation on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had not known that an election…
PLR 1027012: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election but had inadvertently…
PLR 1027011: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election but had inadvertently…
PLR 1027010: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election but had inadvertently…
PLR 1027009: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election but had inadvertently…
PLR 1027008: Foreign entity granted extra time to elect partnership status
The IRS granted a foreign entity an extension of time to elect to be treated as a partnership for federal tax purposes. The entity was eligible for that classification but had failed to timely file…
PLR 1027005: Spouses granted more time to allocate GST exemptions to trust transfers
The IRS granted spouses an extension of time to allocate their generation-skipping transfer tax exemptions to lifetime transfers made to an irrevocable trust. The spouses had reported the transfers…
PLR 1027004: Renewable-energy developer granted more time to elect IDC amortization
The IRS granted a renewable-energy developer an extension of time to elect under section 59(e) to amortize intangible drilling and development costs over 60 months. The developer had delayed filing…
PLR 1027002: Partnership granted relief for late fiscal-year election
The IRS granted a partnership an extension of time to file Form 8716 and elect a tax year ending September 30. The partnership had relied on a qualified tax professional, but its form was filed late…
PLR 1026041: IRS granted more time to recharacterize an ineligible Roth IRA conversion
The IRS granted a taxpayer 60 days to recharacterize a Roth IRA conversion as a contribution to a traditional IRA. The taxpayer and spouse had relied on investment losses that were later challenged…
PLR 1026032: Foreign entity granted extra time to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible for that classification but had failed to…
PLR 1026021: IRS granted more time to allocate GST exemption to earlier trust transfers
The IRS granted a 60-day extension to allocate a decedent's available generation-skipping transfer tax exemption to transfers made to a trust in Years 1 through 6. The taxpayer's accountant had…
PLR 1026020: IRS granted more time to allocate GST exemption to earlier trust transfers
The IRS granted a 60-day extension to allocate a decedent's available generation-skipping transfer tax exemption to transfers made to a trust in Years 1 through 6. The taxpayer's accountant had…
PLR 1026019: IRS granted more time to allocate GST exemption to five trusts
The IRS granted the husband and wife a 60-day extension to allocate their available generation-skipping transfer tax exemptions to transfers made to five trusts. Their tax advisers had prepared…
PLR 1026015: IRS granted more time to elect partnership classification
The IRS granted a foreign business entity an additional 60 days to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to be treated as a partnership…
PLR 1026013: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026012: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026011: IRS granted more time to elect multiple-building low-income housing project treatment
The IRS granted a low-income housing project owner 90 days to make a late election treating all buildings in a project as one multiple-building project under section 42(g)(3)(D). The owner had…
PLR 1026002: IRS granted late-election relief for rental real estate activities
The IRS granted a married couple an additional 60 days to elect to treat all of their rental real estate interests as one rental real estate activity. The taxpayers were eligible to make the…
Extension granted to make a late consolidated-return election
The IRS granted a parent company and related subsidiaries 45 days to make a late election to file a consolidated federal income tax return. The taxpayers showed that they reasonably relied on a…
Sixty-day extension granted for a late IC-DISC election
The IRS granted a domestic corporation 60 days to file a late Form 4876-A election to be treated as an interest charge domestic international sales corporation. The corporation had filed the form 92…
IRS granted extra time for a late IC-DISC election
The IRS considered a domestic corporation that wanted to elect IC-DISC status for its first taxable year but filed Form 4876-A after the applicable 90-day deadline. The delay followed an address…
IRS granted extra time for a GST exemption election
The IRS considered a taxpayer who transferred property to a grantor retained annuity trust and failed to elect out of the automatic allocation of generation-skipping transfer tax exemption on a…
IRS granted extra time for general asset account elections
The IRS considered affiliated taxpayers that had consistently accounted for certain depreciable assets in general asset accounts but inadvertently failed to make the required elections. The IRS…
IRS granted more time to elect U.S. tax deferral for a Canadian retirement plan
The IRS granted a U.S. resident 60 more days to elect to defer U.S. federal income taxation on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had not known that an…
IRS extended time to make a Canadian RRSP tax election
The IRS granted a taxpayer 60 days from the ruling date to make an election under Rev. Proc. 2002-23 to defer U.S. federal income taxation on income accrued in a Canadian Registered Retirement…
IRS granted late partnership classification election
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had intended to be treated as a partnership but…
IRS granted late disregarded-entity classification election
The IRS granted a foreign eligible entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to use that classification…
PLR 1025021: IRS granted more time to make a QTIP election for a trust
The IRS granted a taxpayer 60 days to make a late qualified terminable interest property (QTIP) election for a stock transfer to a trust benefiting the taxpayer's spouse. The taxpayer had timely…
PLR 1025020: IRS allowed a late mark-to-market election for PFIC stock
The IRS granted a common trust fund 60 days to make late mark-to-market elections for stock in four passive foreign investment companies (PFICs). The fund's prior return did not include the required…
PLR 1025019: IRS granted more time to allocate GST exemption to trust transfers
The IRS granted a grantor and spouse 60 days to allocate their generation-skipping transfer (GST) tax exemptions to transfers made to an irrevocable family trust. Their attorney had failed to advise…
PLR 1024071: IRS denied extra time to recharacterize a Roth IRA as a traditional IRA
The IRS denied a request for extra time to recharacterize a Roth IRA as a traditional IRA after the election period had expired. The taxpayer had converted traditional IRAs to a Roth IRA after…
PLR 1024070: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a five-year automatic extension for a plan to amortize unfunded liabilities as of January 1, 2010. The extension applies to the eligible amortization charge bases and is effective…
PLR 1024034: IRS granted more time to make depreciation and drilling-cost elections
The IRS granted a corporate group more time to make two tax elections after a clerical error caused it to miss the filing deadline. The first election concerned whether to claim additional…
PLR 1024033: IRS granted late-election relief for a foreign single-member entity
The IRS granted a foreign single-member entity 60 more days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended that classification…
PLR 1024010: IRS granted more time to allocate GST exemption
A grantor and spouse made transfers to an irrevocable trust but did not allocate generation-skipping transfer tax exemption on their timely filed gift tax returns. The taxpayers represented that no…
PLR 1024009: IRS granted more time to allocate GST exemption
A spouse made several transfers to an irrevocable trust but did not allocate generation-skipping transfer tax exemption on timely filed gift tax returns. The taxpayers represented that no…
PLR 1024007: IRS granted more time to elect disregarded-entity status
A foreign single-member entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS found that the taxpayer acted reasonably and in good…
PLR 1024006: IRS granted more time to allocate GST exemption
A grantor and spouse made transfers to two irrevocable trusts but did not allocate generation-skipping transfer tax exemption to those transfers. The taxpayers relied on an accountant who had not…
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.