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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9100 relief to file a late entity election treating a foreign entity as a partnership
A business entity can choose how it is taxed by "checking the box" on Form 8832, an election called an entity classification election. A foreign entity that is eligible can elect to be treated as a pa…
9100 relief to file a late entity election treating a foreign entity as a partnership
A business entity can choose how it is taxed by "checking the box" on Form 8832, an election called an entity classification election. A foreign entity that is eligible can elect to be treated as a pa…
9100 relief to file a late entity election treating a foreign entity as a partnership
A business entity can choose how it is taxed by "checking the box" on Form 8832, an election called an entity classification election. A foreign entity that is eligible can elect to be treated as a pa…
9100 relief to file two late "check-the-box" elections classifying foreign subsidiaries as disregarded
This letter gives a company extra time to make two late "check-the-box" entity classification elections. A U.S. corporation that had elected S corporation status indirectly owned two foreign subsidiar…
9100 relief to file a late "check-the-box" election classifying a foreign entity as a partnership
This letter grants extra time to make a "check-the-box" entity classification election, a companion to another ruling issued the same week. Under the Section 7701 regulations, an eligible business ent…
9100 relief to file a late "check-the-box" election classifying a foreign entity as disregarded
This letter grants extra time to make a "check-the-box" entity classification election. Under the Section 7701 regulations, an eligible business entity can elect how it is treated for federal tax purp…
A short-term green card holder could not use a treaty to shed U.S. tax residency
A green card holder is a "lawful permanent resident" and therefore a U.S. resident who is taxed on worldwide income until that status is formally given up. This informal Chief Counsel email advice add…
Late relief lets a foreign entity elect to be disregarded from its owner (companion ruling)
This is a companion ruling to PLR 202452002, involving a related foreign company. Like the other one, this foreign company wanted to be treated as a "disregarded entity" for U.S. federal tax purposes …
Late relief lets a foreign entity elect to be disregarded from its owner
A foreign company wanted to be treated as a "disregarded entity" for U.S. federal tax purposes, meaning it would be ignored as separate from its single owner. To do that it had to file Form 8832 (the …
Late relief lets an LLC change from a corporation to a partnership for tax purposes
An LLC had elected to be an S corporation, which under the check-the-box rules also meant it was automatically treated as an association taxable as a corporation. The LLC later wanted to switch to bei…
Late election extended for a foreign entity to be a disregarded entity
A foreign business entity wanted to be treated as a "disregarded entity" for U.S. federal tax purposes, meaning it would be ignored as separate from its single owner. To get that treatment it had to f…
A foreign company gets more time to file the "check-the-box" election making it a disregarded entity
A company formed under the laws of a foreign country wanted to be treated as a disregarded entity for U.S. federal tax purposes, meaning it is ignored as separate from its single owner. That election …
Foreign entity received 120 days to elect corporate classification
A foreign eligible entity intended to be classified as an association taxable as a corporation from its formation date but inadvertently failed to file Form 8832 on time. It represented that the error…
IRS grants 120 days for a late corporate classification election
A single-owner limited liability company was treated by default as disregarded from its owner for federal tax purposes. It intended to change its classification and become an association taxable as a …
LLC receives 120 days to elect corporate tax status
A domestic limited liability company intended to be treated as an association taxable as a corporation from its formation date. It inadvertently failed to file Form 8832 on time and requested late-ele…
Mortgage certificate exchange trust retains fixed investment trust status
A taxpayer proposed exchange trusts that would hold one class of mortgage-backed certificates and issue multiple classes of exchange certificates with different rights to principal and interest. Certi…
Foreign entity receives 120 days to make a late corporate classification election
A foreign eligible entity intended to elect association status so it would be taxed as a corporation for U.S. federal tax purposes, but it did not timely file Form 8832. The entity represented that it…
Foreign entity receives 120 days to make a late corporate classification election
A foreign eligible entity intended to be treated as an association taxable as a corporation for U.S. federal tax purposes but inadvertently failed to timely file Form 8832. The IRS found that the enti…
Late entity classification and tax-exempt controlled entity elections allowed
A limited liability company wholly owned by a section 501(c)(3) organization served as general partner of a partnership that owned an affordable housing project. The operating agreement required the c…
Affordable housing partner received late election relief
A limited liability company owned by a section 501(c)(3) organization was the general partner of a partnership formed to acquire, rehabilitate, own, lease, and manage a qualified low-income housing pr…
IRS lets an LLC change its tax classification again inside the 60-month limit after a majority ownership change
An LLC changed its federal tax classification over time. It began as a two-owner partnership, then became a "disregarded entity" (ignored as separate from its owner) when one owner bought out the othe…
120-day extension for a foreign entity to elect disregarded (check-the-box) status
A foreign entity with a single owner wanted to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes. It could do that by filing a "check-the-box" ele…
Foreign entity received late corporate classification election relief
A foreign eligible entity intended to elect corporate classification for U.S. federal tax purposes but inadvertently failed to file Form 8832 on time. The entity represented that it acted reasonably a…
Late entity classification and S corporation elections allowed
A limited liability company intended from its formation date to be classified as a corporation and taxed as an S corporation. It inadvertently failed to properly and timely file Form 2553. The IRS fou…
Foreign entity allowed late partnership election
A foreign eligible entity intended to elect partnership status for federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for discretionary filing relief were sati…
Foreign entity granted late partnership election
A foreign eligible entity intended to elect partnership status for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the entity met the standards for discreti…
Foreign entity granted late corporate election
A foreign entity converted from an entity classified as a corporation into an eligible entity for U.S. federal tax purposes. It intended to continue corporate treatment but inadvertently failed to fil…
Foreign entity allowed late partnership election
A foreign limited liability partnership defaulted to corporate classification because all its members had limited liability. When a U.S. citizen became a partner, the entity and its owners intended pa…
Late foreign disregarded entity election allowed
A foreign eligible entity intended to be classified as a disregarded entity but inadvertently failed to file Form 8832. The IRS found that the entity satisfied the standards for discretionary filing r…
Foreign entity received 120 days to file a late partnership classification election
A foreign eligible entity 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 entity satisfied the standards …
Foreign entity received 120 days to file a late partnership classification election
A foreign eligible entity 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 entity satisfied the standards …
Foreign entity received 120 days to file a late partnership classification election
A foreign eligible entity 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 entity satisfied the standards …
Foreign entity received 120 days to file a late partnership classification election
A foreign eligible entity 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 entity satisfied the standards …
Foreign entity received 120 days to file a late disregarded-entity classification election
A foreign eligible entity intended to be treated as a foreign disregarded entity for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied th…
Foreign entity received 120 days to file a late disregarded-entity classification election
A foreign eligible entity intended to be treated as a foreign disregarded entity for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied th…
Foreign entity gets more time to elect "disregarded entity" tax treatment
A foreign company wanted to be treated as a "disregarded entity" for U.S. tax purposes, meaning it is ignored as separate from its single owner and its income flows directly to that owner. Under the "…
Foreign entity gets more time to elect corporate ("check-the-box") tax treatment
A foreign company wanted to be treated as a corporation for U.S. tax purposes. Under the "check-the-box" rules in Treasury Regulation 301.7701-3, an eligible entity can choose its own classification b…
LLC gets more time to elect to be disregarded after being acquired by a corporation
An LLC had elected to be an S corporation, which meant it was automatically treated as a corporation (an "association") for tax purposes. A single corporation then bought all of the LLC's units in two…
Foreign entity gets more time to elect to be disregarded from its owner
A U.S. individual formed a foreign entity, which was later transferred to a corporation. By default that foreign entity is treated as a corporation (an "association") for U.S. tax purposes, but the ow…
120-day extension to file a late check-the-box election treating a foreign entity as disregarded
A foreign entity with a single owner wanted to be treated as a disregarded entity (ignored as separate from its owner) for U.S. federal tax purposes. That requires filing Form 8832, the entity-classif…
120-day extension to file a late check-the-box election treating a foreign company as a disregarded entity
A foreign company wanted to be treated as a disregarded entity (ignored as separate from its owner) for U.S. federal tax purposes. To do that it had to file Form 8832, the entity-classification "check…
Extra time granted for a foreign entity to file its corporation (association) election
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A foreign entity here intended to be taxed as an association (that is, as a corporation) as…
Extra time granted for a foreign entity to file its corporation (association) election
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A foreign entity here intended to be taxed as an association (that is, as a corporation) as…
Extra time granted for a foreign entity to file its corporation (association) election
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A foreign entity here intended to be taxed as an association (that is, as a corporation) as…
Extra time granted for a foreign entity to elect corporation (association) status
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A foreign entity here had earlier elected to be disregarded (treated as if it did not exist…
Extra time granted for a foreign entity to elect corporation (association) status
Under the "check-the-box" rules, an eligible business entity can choose how it is taxed by filing Form 8832. A foreign entity here had earlier elected to be disregarded (treated as if it did not exist…
Foreign entity received more time to elect partnership status
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 the failure did not result from tax avoidance or re…
Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but failed to timely file Form 8832. It represented that the failure was not motivated by tax avoidance or…
Foreign entity received more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded from its owner for federal tax purposes but failed to timely file Form 8832. It represented that the failure did not result from tax avo…
Foreign entity received more time to elect disregarded status
A foreign eligible entity intended to be disregarded from its owner for federal tax purposes but failed to timely file Form 8832. The IRS concluded that the entity met the standards for regulatory lat…
Limited partnership received more time to elect partnership status
A domestic limited partnership had previously elected corporate classification and later intended to change back to partnership status. It did not timely file Form 8832, although it and its owners rep…
Foreign entity received more time to elect disregarded status
A foreign entity with one shareholder intended to be disregarded from its owner for federal tax purposes but inadvertently failed to timely file Form 8832. The IRS concluded that the regulatory late-e…
Seven foreign entities received more time to elect partnership status
Seven foreign eligible entities intended to be classified as partnerships for federal tax purposes but did not file Form 8832 for their intended effective dates. Each entity asked for an extension und…
Foreign entity received more time to elect partnership status
A foreign eligible entity intended to be treated as a partnership for federal tax purposes but failed to file Form 8832 on time. The IRS concluded that the entity met the standards for regulatory reli…
Foreign entity received 120 days to make a late disregarded-entity election
A foreign eligible entity failed to timely file Form 8832 to be treated as disregarded from its single owner for federal tax purposes. The IRS found that the entity satisfied the standards for discret…
Foreign entity gets more time to elect partnership status
A foreign limited liability partnership that is eligible to choose how it is classified for U.S. federal tax purposes wanted to be treated as a partnership effective a specific date. To make that choi…
Foreign entity gets more time to elect disregarded-entity status
A foreign business entity that is eligible to choose how it is classified for U.S. federal tax purposes wanted to be treated as a "disregarded entity" (that is, ignored as separate from its single own…
Entity received more time to elect corporate tax classification
An eligible business entity intended to be treated as an association taxable as a corporation but did not timely file Form 8832. The entity represented that it acted reasonably and in good faith and t…
Foreign entity received 120 days for late disregarded-entity election
A foreign eligible entity intended to elect treatment as an entity disregarded from its owner but did not timely file Form 8832. The IRS concluded that the entity satisfied the standards for discretio…
Company received 120 days for late foreign disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its sole owner but inadvertently missed the deadline for filing Form 8832. The entity represented that it acted reasonably and in g…
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.