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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Foreign entity receives relief for a late partnership classification election
A foreign eligible entity intended to be classified as a partnership for federal tax purposes from the date it was organized but did not timely file Form 8832. The entity represented that it acted rea…
Foreign entity receives extra time to elect disregarded status
A foreign entity wholly owned by one owner failed to file Form 8832 on time to elect disregarded-entity status. The IRS concluded that the entity satisfied the standards for discretionary relief under…
Foreign entity receives extra time to elect partnership status
A foreign eligible entity with multiple owners failed to file Form 8832 on time to elect partnership classification for federal tax purposes. The entity represented that it acted reasonably and in goo…
Foreign subsidiary receives late disregarded-entity election relief
A domestic limited liability company formed a wholly owned foreign subsidiary and intended the subsidiary to be disregarded for federal tax purposes from its formation date. The subsidiary failed to t…
Foreign subsidiary receives late disregarded-entity election relief
A domestic limited liability company formed a wholly owned foreign subsidiary and intended the subsidiary to be disregarded for federal tax purposes from its formation date. The subsidiary failed to t…
Foreign entity received extra time to elect disregarded status
A foreign eligible entity with one owner failed to file Form 8832 on time to elect treatment as an entity disregarded from its owner. It represented that it acted reasonably and in good faith and that…
Eligible entity receives 120 days to file a late corporate classification election
A domestic eligible entity intended to be taxed as a corporation from the date it was formed. It failed to file Form 8832 on time because of inadvertence. The IRS concluded that the entity met the req…
LLC receives more time for entity classification and tax-exempt control elections
A tax-exempt organization wholly owned a limited liability company that served as general partner of a partnership operating residential rental property. The LLC intended to elect corporate tax treatm…
LLC receives more time for corporate and depreciation elections
A tax-exempt organization wholly owned a limited liability company that was the general partner of a residential rental partnership. The LLC intended to elect treatment as a taxable corporation and to…
LLC gets late corporate and tax-exempt control elections
A tax-exempt organization owned an LLC that served as general partner of a partnership holding rehabilitated residential rental property. The LLC meant to elect corporate status and opt out of treatme…
Entity receives 120 days to make a late corporate classification election
A domestic eligible entity intended to be treated as an association taxable as a corporation but failed to file Form 8832 on time. The entity represented that it acted reasonably and in good faith and…
Foreign entity receives 120 days to make a late disregarded-entity election
A domestic corporation acquired all interests in a foreign eligible entity that was classified by default as an association. The owner intended the foreign entity to become disregarded for federal tax…
Foreign entity may file a late partnership classification election
A foreign eligible entity defaulted to association status because all of its members had limited liability. It intended to file Form 8832 and elect partnership classification from its formation date b…
Foreign entity receives 120 days to file a late disregarded-entity election
A foreign entity's sole owner intended the entity to be disregarded for federal tax purposes from its formation date. The entity did not timely file Form 8832 to make that classification election. The…
Bankruptcy trust remains a liquidating trust during extended term
A trust was created under a Chapter 11 liquidation plan to recover, sell, and distribute a debtor's remaining assets. Its agreement barred an ongoing business, limited retained cash and investments, r…
Bankruptcy trust keeps liquidating-trust status during two-year extension
A trust established under a Chapter 11 plan had an initial three-year term that the bankruptcy court later extended by two years. The trust existed only to liquidate and distribute estate assets, rest…
Foreign entity receives 120 days to file late corporate classification election
A foreign eligible entity intended to be classified as an association taxable as a corporation from a redacted effective date. It inadvertently failed to file Form 8832 on time. The entity represented…
Bankruptcy trust extension preserves liquidating status
A trust created under a confirmed Chapter 11 plan existed to liquidate and distribute bankruptcy-estate assets. Its agreement limited investments and cash retention, required at least annual distribut…
Foreign entity gets late disregarded classification election
A foreign eligible entity's indirect owner intended the entity to be disregarded for federal tax purposes from its formation date. The entity failed to file Form 8832 on time. The IRS concluded that t…
Foreign entity receives late disregarded status relief
A foreign eligible entity's owner intended the entity to be disregarded for federal tax purposes from its formation date. The entity failed to file Form 8832 on time. The IRS concluded that the entity…
Foreign entity gets late disregarded classification election
A foreign eligible entity's owner intended the entity to be disregarded for federal tax purposes from its formation date. The entity failed to file Form 8832 on time. The IRS concluded that the entity…
Foreign entity receives late disregarded-status election relief
A foreign eligible entity failed to file Form 8832 on time to be treated as a disregarded entity from its formation date. It represented that it acted reasonably and in good faith and that relief woul…
Foreign entity receives late disregarded-status election relief
A foreign eligible entity failed to file Form 8832 on time to be treated as a disregarded entity from its formation date. It represented that it acted reasonably and in good faith and that relief woul…
Foreign entity receives extension for classification election
A foreign limited liability company wanted a federal tax classification different from its default status but inadvertently failed to file Form 8832 on time. The IRS found that the entity met the stan…
LLC receives extension to elect corporate classification
A domestic limited liability company was eligible to elect treatment as an association taxable as a corporation but did not timely file Form 8832. The IRS found that the company satisfied the standard…
Foreign entity granted late partnership election
A foreign entity with two owners intended to elect partnership classification for federal tax purposes but did not timely file Form 8832. It represented that it was an eligible foreign entity and requ…
Late disregarded-entity election receives a 120-day extension
A foreign eligible entity failed to file Form 8832 on time to be treated as a disregarded entity from its intended effective date. It represented that it had acted reasonably and in good faith and tha…
Late disregarded-entity election receives a 120-day extension
A foreign eligible entity's owner intended the entity to be classified as a disregarded entity from its formation date, but the entity did not file Form 8832 on time. The IRS concluded that the entity…
Late partnership-classification election receives a 120-day extension
The owners of a foreign eligible entity intended it to be classified as a partnership from its formation date, but the entity did not file Form 8832 on time. The IRS concluded that the entity satisfie…
Foreign entity allowed an early classification change
A foreign eligible entity asked for consent to change its federal tax classification from a corporation to a partnership less than 60 months after its prior election. The entity represented that more …
Foreign entity allowed an early classification change
A foreign eligible entity asked for consent to change its federal tax classification from a corporation to a partnership less than 60 months after its prior election. The entity represented that more …
Foreign entity allowed an early change to disregarded status
A foreign eligible entity asked for consent to change its federal tax classification from a corporation to a disregarded entity less than 60 months after its prior election. The entity represented tha…
Late entity classification election granted 9100 relief
A limited liability company asked for additional time to elect disregarded-entity status after its sole owner acquired it. The company and its owner had filed their relevant returns consistently with …
Bankruptcy liquidating trust allowed a three-year extension
A trust created under a Chapter 11 liquidation plan needed more time to finish recovering, liquidating, and distributing its assets. Its governing agreement required a favorable IRS ruling before exte…
Foreign entity allowed an early change to disregarded status
A foreign eligible entity asked for consent to change its federal tax classification from a corporation to a disregarded entity less than 60 months after its prior election. The entity represented tha…
Entity received extensions for corporate classification and tax-exempt control elections
A limited liability company wholly owned by a section 501(c)(3) organization missed two intended elections. It failed to file Form 8832 for corporate tax classification and also failed to elect under …
Late corporate classification election received a 120-day extension
A limited liability company intended to be classified as an association taxable as a corporation before later converting into a state-law corporation. It failed to file Form 8832 on time and requested…
Foreign entity receives late disregarded-entity election relief
A foreign eligible entity wholly owned by a U.S. corporation intended to be treated as a disregarded entity but failed to timely file Form 8832. The IRS found that the entity met the standards for dis…
Foreign entity receives late disregarded-entity election relief
A foreign eligible entity wholly owned by a U.S. corporation intended to be treated as a disregarded entity but failed to timely file Form 8832. The IRS found that the entity met the standards for dis…
Foreign entity receives late partnership-classification relief
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. It represented that it was eligible to elect partnership status effecti…
Foreign entity receives more time for disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner but did not timely file Form 8832. The entity represented that it acted reasonably and in good faith and that granting re…
Foreign entity receives more time for disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner but did not timely file Form 8832. The entity represented that it acted reasonably and in good faith and that granting re…
Foreign entity receives more time for disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner but did not timely file Form 8832. The entity represented that it acted reasonably and in good faith and that granting re…
Extended term does not end liquidating trust treatment
A trust was created under a Chapter 11 reorganization plan to liquidate and distribute a debtor's estate. After an initial three-year term and a two-year extension, developments generally beyond the t…
Foreign entity gets 120 days to elect partnership status
A foreign business entity with multiple owners intended from formation to be treated as a partnership for federal tax purposes. It failed to file Form 8832 on time to elect that classification effecti…
LLC may change classification and file a late election
A domestic limited liability company had elected corporate tax treatment and was later acquired entirely by an unrelated corporate owner. The acquisition changed more than 50 percent of the LLC's owne…
Employees of a disregarded LLC may join the tax-exempt owner's retirement plans
Chief Counsel considered whether employees of a disregarded single-member LLC could participate in retirement plans sponsored by its tax-exempt owner. Because the LLC is treated as a branch or divisio…
Foreign entity receives more time to elect disregarded status
A foreign entity wholly owned by a U.S. corporation intended to be treated as a disregarded entity but did not timely file Form 8832. The IRS found that the entity met the standards for discretionary …
Foreign entity receives more time to elect partnership status
A foreign entity with multiple owners intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The IRS found that the entity met the standards for discret…
Foreign entity receives more time to elect partnership status before acquisition
A foreign entity with several owners intended to elect partnership classification effective before its later acquisition by a corporate owner, but it did not timely file Form 8832. The IRS found that …
Foreign entity receives more time to elect disregarded status
A foreign entity with one corporate owner intended to be treated as a disregarded entity for federal tax purposes, and its corporate group filed consolidated returns consistent with that treatment. Th…
Territory entity receives late disregarded-status election relief
An entity organized under the laws of a U.S. territory became wholly owned by one owner and intended to be treated as a disregarded entity from that date. It did not timely file Form 8832. The IRS fou…
Single-owner entity gets late disregarded-status election relief
An entity organized under the laws of a U.S. territory became wholly owned by one owner and intended to be disregarded for federal tax purposes from that date. The entity missed the deadline to file F…
Foreign entity receives late corporate-classification election relief
A foreign eligible entity intended to elect association status and be taxed as a corporation from its formation date, but it did not timely file Form 8832. The IRS concluded that the entity met the re…
Foreign entity receives late partnership-classification relief
A foreign eligible entity intended to be classified as a partnership from its formation date but did not timely file Form 8832. The IRS concluded that the entity met the reasonable-cause standards for…
Foreign entity receives more time to elect disregarded status
A foreign eligible entity was wholly owned by an S corporation through a qualified subchapter S subsidiary. The owners intended from formation to treat the foreign entity as disregarded for federal ta…
Entity receives more time to elect corporate classification
A business entity intended from its formation date to be treated as an association taxable as a corporation for federal tax purposes. It inadvertently failed to file Form 8832 by the deadline. The IRS…
Entity receives 120 days to file late corporate classification election
An eligible business entity intended from its formation date to be treated as an association taxable as a corporation. Through inadvertence, it did not timely file Form 8832 to make that classificatio…
A foreign entity received 120 days for a partnership election
A foreign eligible entity whose owners all had limited liability intended to be classified as a partnership from its formation date. It failed to file Form 8832 on time because of inadvertence, while …
A foreign entity received 120 days for a partnership election
A foreign entity with two owners intended to be classified as a partnership from its formation date but failed to file Form 8832 on time. The IRS found the section 301.9100-3 relief standards satisfie…
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.