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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Late disregarded-entity election received relief
A business entity owned all of a second entity and intended the subsidiary to be treated as disregarded for federal tax purposes from its formation date. The subsidiary inadvertently failed to file Fo…
Late partnership-classification election received relief
A foreign eligible entity with two owners intended to elect partnership classification for federal tax purposes but did not timely file Form 8832. The IRS concluded from the submitted information and …
Dormant LLC's corporate election treated as initial classification
A limited liability company remained dormant after formation, with no assets, income, liabilities, bank accounts, operations, or board meetings. Before it acquired property and began business, it file…
Foreign entity granted late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes. It failed to file Form 8832 on time for the desired effective date. The entity requested a…
Foreign company received late disregarded-entity election relief
A foreign eligible entity intended to be classified as disregarded from its owner for federal tax purposes. It did not timely file Form 8832 for the intended effective date. The entity asked the IRS f…
Foreign entity allowed a late disregarded-entity election
A foreign eligible entity planned to be treated as disregarded from its owner for U.S. federal tax purposes. It failed to submit Form 8832 by the deadline for its intended effective date. The entity r…
Rental-property co-ownership was not a business entity
A taxpayer planned to sell a tenancy-in-common interest in an office rental property to an unrelated co-owner while retaining the remaining interest. Their agreement required proportional sharing of r…
Foreign entity receives extra time to elect corporate classification
A foreign eligible entity intended to be treated as a corporation for federal tax purposes but did not timely file Form 8832. It asked the IRS for additional time to make the entity-classification ele…
Foreign entity receives extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership for U.S. federal tax purposes but did not timely file Form 8832. It requested additional time to make the entity-classification electi…
Foreign entity receives extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership for U.S. federal tax purposes but did not timely file Form 8832. It requested additional time to make the entity-classification electi…
Foreign entity receives extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership for an earlier period but did not timely file Form 8832. It also represented that it later became eligible to be disregarded from its …
Foreign entity receives extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership for U.S. federal tax purposes but did not timely file Form 8832. It requested additional time to make the entity-classification electi…
Foreign entity receives extra time to elect partnership classification
A foreign eligible entity intended to be treated as a partnership for U.S. federal tax purposes but did not timely file Form 8832. It requested additional time to make the entity-classification electi…
IRS grants 90 days for a late partnership-classification election
A domestic limited liability company intended to elect partnership treatment for federal tax purposes, effective on a redacted date, but did not timely file Form 8832. Entity-classification elections …
Bankruptcy trust keeps liquidating-trust status during another extension
A trust created under a Chapter 11 plan had received several court-approved extensions because it could not finish liquidating the debtor's assets within its original term. Its agreement limited activ…
Foreign entity receives late disregarded-entity election relief
A foreign entity wholly owned by a resident alien missed the deadline to file Form 8832 electing to be treated as a disregarded entity for federal tax purposes. The entity had acquired real property i…
Foreign entity receives late disregarded-entity election relief
A foreign entity's indirect owner intended the entity to be disregarded for federal tax purposes from its formation date, but the entity inadvertently failed to file Form 8832 on time. The IRS conclud…
Foreign entity receives 120 days for a late corporate classification election
A foreign entity owned through a qualified Subchapter S subsidiary intended to be classified as an association taxable as a corporation from a specified date. It failed to timely file Form 8832 to mak…
LLC receives 120 days for a late corporate classification election
A two-member entity converted into a limited liability company and intended to be treated as an association taxable as a corporation from the conversion date. It inadvertently failed to timely file Fo…
Foreign entity receives 120 days for a late change to corporate status
A foreign eligible entity had previously made an entity-classification election and later intended to change its classification to an association taxable as a corporation from a specified date. It did…
Foreign entity receives 120 days to elect corporate classification
A foreign eligible entity owned within a consolidated group did not make an entity-classification election when it was formed. It later sought to be classified as an association taxable as a corporati…
Foreign entity receives 120 days for a late disregarded-entity election
A foreign entity became wholly owned through an individual who became a U.S. tax resident on a specified date. The entity was eligible and intended to be treated as disregarded from that date but fail…
Foreign company receives late disregarded-entity election relief
A foreign entity was wholly owned by an individual who became a U.S. tax resident on a specified date. The entity intended to be disregarded for federal tax purposes from that date but inadvertently f…
Extended bankruptcy trust remains a liquidating trust
A trust created under a Chapter 11 bankruptcy plan was established to liquidate and distribute a debtor's remaining assets. Developments largely beyond the trustee's control required more time to reco…
Single-owner entity receives late disregarded-entity election
A single-owner eligible entity intended to be treated as disregarded for federal tax purposes but did not file the required Form 8832. The IRS concluded that the entity satisfied the standards for dis…
Foreign entity receives late disregarded-entity election
A foreign eligible entity wholly owned by a U.S. citizen failed to file Form 8832 for its intended disregarded-entity status. The IRS concluded that the entity met the standards for discretionary elec…
Foreign entity receives late disregarded-entity election
A foreign eligible entity wholly owned by a U.S. citizen failed to file Form 8832 for its intended disregarded-entity status. The IRS concluded that the entity met the standards for discretionary elec…
Foreign limited partnership may make a late corporate classification election
A foreign limited partnership intended to be treated as an association taxable as a corporation for U.S. federal tax purposes, but it inadvertently failed to file Form 8832. Without an election, the e…
LLC receives 120 days to file entity-classification election
A single-member LLC intended to be treated as a disregarded entity for federal tax purposes but did not timely file the entity-classification election. It represented that it acted reasonably and in g…
Late disregarded-entity election receives 120-day extension
A single-member LLC intended to be treated as a disregarded entity but did not timely file Form 8832. It represented that it acted reasonably and in good faith and that granting relief would not preju…
Foreign entity receives 120 days for disregarded status election
A foreign entity wholly owned by a foreign trust intended to be treated as disregarded from its owner for federal tax purposes, but it did not timely file Form 8832. The entity requested relief under …
Foreign entity receives late disregarded status election
A foreign eligible entity intended to elect disregarded-entity treatment from its formation date but inadvertently failed to file Form 8832 on time. Its ownership changed among related foreign entitie…
Entity receives late association election
A domestic eligible entity intended to be treated as an association taxable as a corporation from its formation date but failed to file Form 8832 on time. Its owner consistently treated the entity as …
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late disregarded status election
A foreign eligible entity failed to timely file a properly executed Form 8832 electing to be disregarded from its owner for federal tax purposes. The entity represented that it acted reasonably and in…
Foreign entity receives late partnership election relief
A foreign eligible entity intended to be treated as a partnership beginning when U.S. persons became its direct and indirect owners, but it did not timely file Form 8832. The IRS concluded that the en…
Foreign entity receives late disregarded status election
A foreign eligible entity intended to be treated as disregarded from its owner for federal tax purposes but inadvertently failed to timely file Form 8832. The entity represented that it acted reasonab…
Foreign entity receives late disregarded status election
A foreign eligible entity intended to be treated as disregarded from its owner for federal tax purposes but inadvertently failed to timely file Form 8832. The entity represented that it acted reasonab…
Foreign entity receives late partnership election relief
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but failed to timely file Form 8832. The IRS concluded from the submitted facts and representations that the …
Foreign entity receives extension for disregarded-entity election
A foreign entity's owner intended the entity to be treated as disregarded for federal tax purposes from a specified date, but the entity failed to timely file Form 8832. The IRS found that the section…
LLC receives 120 days to elect corporate classification
A single-owner limited liability company intended to be classified as an association taxable as a corporation but did not timely file Form 8832. The company represented that its federal tax and inform…
Foreign entity receives 120 days to elect partnership status
A foreign entity whose owners all had limited liability intended to be classified as a partnership for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the r…
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.