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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.

10,109 determinations and counting · Newest release July 31, 2026
306 determinations Partnerships

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PLR

Partnership receives 120 days to make a late section 754 election

A partnership distributed property to a retiring partner and intended to elect under section 754 to adjust partnership property basis, but it inadvertently omitted the election from its timely return.…

202005014·January 31, 2020
Approved
PLR

Partnership gets 120 days for late Section 754 elections

A foreign-law general partnership failed to make timely section 754 elections for two taxable years after an investor acquired an interest in an upper-tier partnership that owned part of it. The partn…

201950002·December 13, 2019
Approved
PLR

Partnership gets 120 days for late Section 754 elections

A foreign-law general partnership failed to make timely section 754 elections for two taxable years after a purchaser acquired an interest in it. The partnership represented that it acted reasonably a…

201950001·December 13, 2019
Approved
PLR

Partnership gets 120 days for election after partner's death

A limited partnership failed to make a section 754 election after a deceased partner's interest passed to an estate. The partnership had relied on its tax adviser and did not know it was eligible to m…

201949010·December 6, 2019
Approved
PLR

Partnership allowed late section 754 election

A foreign limited partnership made liquidating distributions to three partners but did not attach a section 754 election to its timely filed return because its tax preparers failed to explain the elec…

201947014·November 22, 2019
Approved
PLR

Partnership receives 120 days for late Section 754 election

A limited liability company taxed as a partnership did not include a section 754 election with its timely return for the year one of its two owners died. Its professional return preparer had not told …

201945023·November 8, 2019
Approved
PLR

Partnership received 120 days to make a late section 754 election

A limited liability company taxed as a partnership timely filed its return but inadvertently omitted a valid section 754 election. It represented that it acted reasonably and in good faith and that la…

201943017·October 25, 2019
Approved
PLR

Partnership received 120 days to make a late section 754 election

A limited liability company treated as a partnership missed a section 754 election after an owner died because its advisor did not explain that the election was available. The IRS found that the regul…

201937012·September 13, 2019
Approved
PLR

Partnership received late section 754 election relief after partner deaths

A limited partnership failed to make a timely section 754 election for three years in which deaths affected partnership interests. It represented that it acted reasonably and in good faith and that re…

201934002·August 23, 2019
Approved
PLR

Partnership received extension for section 754 election

A limited liability company taxed as a partnership failed to make a timely section 754 election for the year in which ownership interests were transferred. The company represented that it acted reason…

201933002·August 16, 2019
Approved
TAM

Assets-over merger required a downward partnership basis adjustment

Two partnerships merged using the assets-over form, with the terminating partnership deemed to contribute its assets and liabilities and then distribute an interest in the resulting partnership to its…

201929019·July 19, 2019
Advice
PLR

Partnership received 120 days to make a section 754 election

A limited liability company treated as a partnership intended to make a section 754 election for the year in which an investor purchased an interest, but it did not file the election on time. The part…

201929016·July 19, 2019
Approved
PLR

IRS retroactively revoked late section 754 election relief

The IRS had previously given a taxpayer 120 days to make a late section 754 election. That relief was based on a representation that no affected return was under examination, before Appeals, or before…

201927012·July 5, 2019
Revocation
PLR

Partnership received late section 754 election relief

A partnership timely filed its return for a year in which partnership interests had been transferred but inadvertently omitted a section 754 election. The IRS granted 120 days to file the election for…

201926003·June 28, 2019
Approved
PLR

Partnership received 120 days to make late section 754 election

A limited partnership failed to make a timely section 754 election for a year in which partnership interests were treated as transferred. The partnership represented that it acted reasonably and in go…

201924012·June 14, 2019
Approved
PLR

Partnership received 120 days for section 754 election after partner's death

A limited liability company classified as a partnership timely filed its return for the year in which a partner died but inadvertently omitted a valid section 754 election. The partnership represented…

201924010·June 14, 2019
Approved
PLR

Foreign partnership received 120 days for section 754 election

A foreign limited partnership failed to make a timely section 754 election for a year in which partnership interests were transferred. It represented that it acted reasonably and in good faith, was no…

201924008·June 14, 2019
Approved
PLR

Partnership received 120 days to file omitted section 754 election

A state-law partnership timely filed its federal return but inadvertently omitted a valid section 754 election to adjust the basis of partnership property. It represented that it acted reasonably and …

201924007·June 14, 2019
Approved
PLR

Partnership gets 120 days to make late section 754 election

A partnership timely filed its return for the year in which a partner died but inadvertently omitted a section 754 election. The IRS concluded that the requirements for discretionary filing relief wer…

201923015·June 7, 2019
Approved
PLR

Partnership received 120 days to make a section 754 election

A partnership admitted a purchaser of a membership interest but did not make a section 754 election with its timely return for that year. The partnership relied on a tax professional, was unaware that…

201920010·May 17, 2019
Approved
PLR

Partnership received 120 days to make late section 754 election

A partnership had made a section 754 election before a technical termination but failed to make a valid election for the post-termination period. Although it attached a statement showing section 743(b…

201919010·May 10, 2019
Approved
PLR

Lower-tier partnership received late section 754 election relief

An upper-tier partnership had a section 754 election in effect when one of its partners sold an interest to a new partner. The lower-tier partnership, in which the upper-tier partnership held an inter…

201919007·May 10, 2019
Approved
PLR

Partnership gets extra time to make a missed Section 754 election after a partner's death split the owner trust

An LLC taxed as a partnership had one interest held through a revocable living trust treated as owned by a married couple. When one spouse died, that trust split into several successor trusts, an even…

201918011·May 3, 2019
Approved
CCA

Partnership anti-abuse rule lets the IRS collapse a partnership to tax an offshore IP transfer under Section 367(d)

When a U.S. company moves intangible property (like patents) to a foreign corporation, Section 367(d) makes it pay U.S. tax on that value, either as a deemed royalty spread over the property's life (t…

201917007·April 26, 2019
Advice
PLR

Partnership gets extra time to make a missed Section 754 basis-adjustment election

A partnership meant to make a Section 754 election, which lets it adjust the inside basis of its assets when interests change hands or property is distributed, so that later gain or loss lines up with…

201917003·April 26, 2019
Approved
PLR

120-day extension granted to make a late § 754 basis-adjustment election

A partnership can make a § 754 election that lets it adjust the tax basis of its property when a partnership interest changes hands (for example, when a partner dies) or when property is distributed. …

201909004·March 1, 2019
Approved
PLR

Late relief granted for a foreign-formed partnership to make a section 754 basis-adjustment election

A section 754 election lets a partnership adjust the tax basis of its assets after a partner is admitted or an interest changes hands, so the incoming partner's inside basis lines up with the value re…

201904013·January 25, 2019
Approved
PLR

Late relief granted for a foreign-formed partnership to make a section 754 basis-adjustment election

A section 754 election lets a partnership adjust the tax basis of its assets after a partner is admitted or an interest changes hands, so the incoming partner's inside basis lines up with the value re…

201904012·January 25, 2019
Approved
PLR

Partnership gets 120 days to make a late Section 754 election

A limited partnership intended to make an IRC § 754 election after a partner died but failed to include a properly executed election with its return. The partnership represented that the failure was i…

201902025·January 11, 2019
Approved
PLR

Partnership gets 120 extra days to make a late Section 754 basis-adjustment election

A limited partnership meant to make a Section 754 election, which lets a partnership adjust the tax basis of its assets after a partner dies or a partnership interest changes hands, so the new owner i…

201852013·December 28, 2018
Approved
PLR

Lower-tier partnership gets 120 extra days to make a late Section 754 election

A partner in an upper-tier partnership died, and both that partnership and a lower-tier partnership it partly owned failed to make timely Section 754 elections for the year. The lower-tier partnership…

201851007·December 21, 2018
Approved
PLR

Upper-tier partnership gets 120 extra days to make a late Section 754 election

A partner in an upper-tier partnership died, and both that partnership and a lower-tier partnership it partly owned failed to make timely Section 754 elections for the year. The upper-tier partnership…

201851006·December 21, 2018
Approved
PLR

Partnership receives 120 days to make a late section 754 election

A partnership intended to make a section 754 election after ownership interests were transferred but failed to attach a properly executed election to its return. The partnership and all affected partn…

201848014·November 30, 2018
Approved
PLR

IRS grants a partnership extra time to make a late § 754 basis-adjustment election after its preparer failed to advise it

When a partner dies or a partnership interest changes hands, a partnership can make a "§ 754 election" to adjust the tax basis of its property, which often lets the remaining or incoming partners clai…

201846003·November 16, 2018
Approved
CCA

An enforceable owner note can count toward a disregarded entity's net value

Chief Counsel considered how to compute the “net value” of a disregarded entity that held an intercompany note from its corporate owner. Treas. Reg. § 1.752-2(k) treats a disregarded entity as separat…

201841006·October 12, 2018
Advice
PLR

Grants 120 days for a late section 754 election after a partnership-interest transfer

A limited liability company taxed as a partnership timely filed its return for a year in which one member transferred part of its interest to another member, but it did not attach a section 754 electi…

201841003·October 12, 2018
Approved
PLR

Partnership gets a late section 754 election after a member bought out another, subject to basis-adjustment conditions

An LLC taxed as a partnership had one member transfer her entire interest to another member. The partnership filed its return for that year on time but did not include the § 754 election that would le…

201840005·October 5, 2018
Approved
PLR

Partnership gets more time to make a section 754 basis-adjustment election it filed its returns as if it had made

A § 754 election lets a partnership adjust the basis of its assets after a partner's interest changes hands, matching inside basis to what happened at the partner level. The election has to be filed w…

201840003·October 5, 2018
Approved
PLR

Partnership gets more time to make a section 754 basis-adjustment election it missed

When someone buys into a partnership, the partnership can make a § 754 election so the new partner's share of the partnership's assets gets a basis adjustment that matches what they paid, which usuall…

201839004·September 28, 2018
Approved
PLR

Grants 120 days for late section 754 election

A limited partnership failed to make a timely section 754 election for the year in which one of its partners died. The partnership represented that the omission was inadvertent, that it acted reasonab…

201834004·August 24, 2018
Approved
PLR

Grants extension for omitted section 754 election

A partnership failed to include a section 754 election with its return for the year an individual partner died. The partnership represented that the omission was inadvertent, that it acted reasonably …

201833007·August 17, 2018
Approved
PLR

Partnership received 120 days to make late Section 754 election

A professional-services limited liability company treated as a partnership missed the deadline to make a Section 754 election for the year in which a buyer acquired a partnership interest. The partner…

201830010·July 27, 2018
Approved
PLR

Partnership receives 120 days to make a late Section 754 election

A partnership failed to make a Section 754 election for the year in which one owner sold its interest to the remaining and incoming owners. The election would permit a transferee-specific adjustment t…

201826008·June 29, 2018
Approved
PLR

Partnership receives 120 days to make a late Section 754 election

A partnership failed to make a Section 754 election for the year in which one owner sold its interest to the remaining and incoming owners. The election would permit a transferee-specific adjustment t…

201826007·June 29, 2018
Approved
PLR

Partnership receives 120 days to make a late Section 754 election

A partnership failed to make a Section 754 election for the year in which one owner sold its interest to the remaining and incoming owners. The election would permit a transferee-specific adjustment t…

201826005·June 29, 2018
Approved
PLR

Lower-tier partnership received 120 days for late Section 754 election

A partner in an upper-tier partnership died. The upper-tier partnership timely elected under Section 754, but a lower-tier partnership in which it held an interest inadvertently failed to make the sam…

201823001·June 8, 2018
Approved
PLR

Partnership received time for Section 754 election after partner's death

A general partnership intended to make a Section 754 election after one of two spouses who owned a partnership interest as community property died. The partnership did not timely file the return makin…

201819010·May 11, 2018
Approved
PLR

Partnership received time for election after technical termination

A limited liability company taxed as a partnership underwent a technical termination under former Section 708(b)(1)(B) when one owner sold membership interests to two buyers. The partnership intended …

201819005·May 11, 2018
Approved
PLR

Partnership received 120 days to make a late Section 754 election

A limited partnership failed to include a Section 754 election with its return for the year in which one partner sold its interest to another party. The partnership represented that the omission was i…

201818007·May 4, 2018
Approved
PLR

Partnership received relief for a late Section 754 election

A limited liability company treated as a partnership underwent a technical termination after a transfer of ownership interests. It intended to make a Section 754 election in connection with that trans…

201818003·May 4, 2018
Approved
PLR

Partnership received 120 days for a late Section 754 election

A partner died, causing that partner's interest and a terminating trust's separate interest in a partnership to pass to new owners. The partnership relied on its tax adviser and did not know that it c…

201817018·April 27, 2018
Approved
PLR

Partnership received 120 days to make a late Section 754 election

A limited partnership timely filed its federal tax return but inadvertently failed to include an election under Section 754. The partnership represented that it acted reasonably and in good faith and …

201816006·April 20, 2018
Approved
PLR

Grants 120 days to make late partnership basis election

A partnership wanted a section 754 election after a general partner died, but its tax return was filed without the election because it relied on its tax adviser. The partnership represented that it ac…

201815002·April 13, 2018
Approved
PLR

Grants 120 days to file omitted section 754 election

A foreign corporation treated as a partnership for U.S. tax purposes intended to make a section 754 basis-adjustment election with its return, but failed to file a properly executed election. The enti…

201814008·April 6, 2018
Approved
PLR

Grants extra time for a partnership's section 754 election

A partnership underwent a technical termination after an owner acquired an additional interest. The partnership intended to elect under section 754 to adjust the basis of partnership property for the …

201812004·March 23, 2018
Approved
PLR

Partnership receives 120 days to make a late Section 754 election

A lower-tier partnership sought extra time to make a section 754 election after a partner in its upper-tier partnership died. Both partnerships timely filed their returns, but an adviser inadvertently…

201811012·March 16, 2018
Approved
PLR

Upper-tier partnership receives 120 days to make a late Section 754 election

An upper-tier partnership sought extra time to make a section 754 election after one of its partners died. The upper-tier partnership and a lower-tier partnership timely filed their returns, but an ad…

201811011·March 16, 2018
Approved
PLR

Partnership-to-REIT asset transfers qualify for specified nonrecognition treatment

A publicly traded partnership planned to form a real estate investment trust and contribute substantially all of its operating assets to the new REIT. It would later acquire more assets through a fund…

201810005·March 9, 2018
Approved
PLR

Acquirer may close its books on the acquisition date to allocate losses under section 384

A publicly traded holding company acquired a corporation with built-in gains through a merger and then contributed the surviving merger subsidiary to a partnership it controlled. Both the holding comp…

201806005·February 9, 2018
Approved
PLR

Partnership receives 120 days to file a late section 754 basis-adjustment election

A partnership timely filed its federal return but inadvertently omitted a section 754 election to adjust the basis of partnership property. Such an election applies section 734 adjustments to property…

201804006·January 26, 2018
Approved

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.