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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Taxpayer granted 60 days to file the correct Form 3115
The IRS granted a taxpayer an extension of time to file the signed original of Form 3115, Application for Change in Accounting Method. The taxpayer had submitted the correct signed duplicate to the…
Taxpayer granted more time to elect Canadian RRSP tax deferral
The IRS granted a taxpayer an extension of time to elect treaty-based deferral of U.S. tax on income accrued in a Canadian Registered Retirement Savings Plan. The taxpayer had become a U.S.…
Foreign entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had been eligible to make the election but inadvertently…
Foreign entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had been eligible to make the election but inadvertently…
Foreign entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity had been eligible to make the election but inadvertently…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to elect partnership classification for federal tax purposes. The entity was eligible to make the election but inadvertently failed to…
Foreign eligible entity granted more time to elect partnership classification
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect partnership classification for federal tax purposes. The entity intended to be treated as a partnership but…
Entity granted more time to elect disregarded-entity status
The IRS granted an entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes, effective on an earlier specified date. The entity was eligible to…
Entity granted more time to elect disregarded-entity status
The IRS granted an entity 60 days to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes, effective on an earlier specified date. The entity was eligible to…
Estate granted more time for GST allocation and reverse QTIP election
The IRS granted an estate 60 more days to allocate the decedent's generation-skipping transfer tax exemption to two trusts and to make a reverse QTIP election for the exempt marital trust. The…
Extension granted to recharacterize a Roth IRA conversion
The IRS granted a taxpayer 60 additional days to recharacterize a Roth IRA conversion as a contribution to a traditional IRA. An examination later increased the taxpayers' modified adjusted gross…
PLR 1022003: Taxpayers receive more time to allocate GST tax exemptions to trust transfers
The IRS granted spouses an additional 60 days to allocate their generation-skipping transfer tax exemptions to gifts made to four trusts for their children and descendants. The taxpayers had split…
PLR 1022002: Estate receives more time to elect a family-owned business deduction
The IRS granted an estate an additional 60 days to make an election under former § 2057 for a deduction for qualified family-owned business interests. The decedent had operated residential apartment…
PLR 1021017: IRS granted more time to make an election relinquishing a consolidated NOL carryback
The IRS granted a corporate taxpayer an extension of time to file an election relinquishing the entire carryback period for a consolidated net operating loss. The taxpayer intended to make the…
PLR 1021012: IRS granted more time to allocate generation-skipping transfer tax exemptions
The IRS granted a married couple an extension of time to allocate their generation-skipping transfer tax exemptions to transfers made to three trusts. Their attorneys and accountant reported the…
PLR 1021001: IRS granted relief for a late Form 1128 filing
The IRS granted a taxpayer relief for filing Form 1128 late. The form requested a change from a 52-53-week taxable year ending near January 31 to a calendar year ending December 31. The IRS found…
PLR 1020002: IRS granted extra time to make a QTIP election
The IRS granted an executor an extension of time to make a qualified terminable interest property election under IRC § 2056(b)(7). The executor had filed the decedent's estate tax return and…
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.