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 120 days to make a late disregarded-entity election
A foreign entity with one owner intended to be treated as disregarded for U.S. federal tax purposes from the date it incorporated, but it did not timely file Form 8832. Its owner consistently reported…
Foreign entity receives 120 days to file a late disregarded-entity election
A foreign limited company eligible to choose its U.S. federal tax classification inadvertently failed to file Form 8832 on time to be treated as a disregarded entity from its intended date. It represe…
IRS grants foreign entity more time to elect partnership status
A foreign entity with owners having limited liability intended to be treated as a partnership for federal tax purposes from its formation date. It failed to file Form 8832 on time because of inadverte…
IRS allows late disregarded-entity election after inadvertent filing failure
A foreign limited company intended to be treated as a disregarded entity for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that the request did not involve hi…
IRS grants foreign company late disregarded-entity election
A foreign limited company intended to elect disregarded-entity treatment for federal tax purposes but inadvertently missed the Form 8832 deadline. It represented that it acted reasonably and in good f…
IRS grants foreign entity late disregarded-entity election
A foreign parent transferred ownership of a foreign entity through a restructuring that ultimately placed the entity under a newly formed U.S. corporation. On the relevant date, the entity was a forei…
IRS grants foreign entity late partnership election
A foreign eligible entity became owned by two foreign entities with limited liability before its ownership was transferred directly and indirectly under a newly formed U.S. corporation. Its default fe…
IRS grants foreign entity late disregarded classification
A foreign eligible entity intended to be disregarded as separate from its owner for federal tax purposes but inadvertently missed the Form 8832 deadline. It represented that it acted reasonably and in…
IRS grants late disregarded-entity election relief
A parent company wholly owned a foreign eligible entity and intended to classify it as disregarded for federal tax purposes. Form 8832 was not filed on time because of inadvertence, although all relev…
Foreign entity gets 120 days to file a late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes but inadvertently failed to file Form 8832 with the intended effective date. The IRS conclu…
Foreign entity receives late partnership election relief
A foreign eligible entity had two owners with limited liability, so its default federal tax classification was an association taxable as a corporation. It intended to be classified as a partnership fr…
Foreign entity gets 120 days for disregarded-entity election
A foreign limited company inadvertently failed to file Form 8832 on time to elect treatment as an entity disregarded from its owner. The IRS found that the entity acted reasonably and in good faith an…
Foreign entity gets 120 days for partnership election
A foreign limited company inadvertently failed to file Form 8832 on time to elect partnership treatment. The IRS found that the entity acted reasonably and in good faith and that relief would not prej…
Foreign entity gets 120 days for disregarded-entity election
A foreign limited company inadvertently failed to file Form 8832 on time to elect treatment as an entity disregarded from its owner. The IRS found that the entity acted reasonably and in good faith an…
Foreign entity gets 120 days for partnership election
A foreign limited company inadvertently failed to file Form 8832 on time to elect partnership treatment. The IRS found that the entity acted reasonably and in good faith and that relief would not prej…
Foreign entity gets 120 days for disregarded-entity election
A foreign limited company inadvertently failed to file Form 8832 on time to elect treatment as an entity disregarded from its owner. The IRS found that the entity acted reasonably and in good faith an…
Foreign entity gets 120 days for partnership election
A foreign limited company inadvertently failed to file Form 8832 on time to elect partnership treatment. The IRS found that the entity acted reasonably and in good faith and that relief would not prej…
Foreign entity receives more time for disregarded-entity election
A foreign entity wholly owned by a domestic corporation intended to be treated as a disregarded entity, and its owner consistently filed on that basis, but Form 8832 was not timely filed. The IRS foun…
LLC receives 120 days to file a late corporate-classification election
A state-law limited liability company intended to be treated as an association taxable as a corporation from a specified date. It missed the Form 8832 filing deadline because of inadvertence and asked…
Supplemental ruling revises the facts of an earlier entity-classification ruling
This supplemental private letter ruling modifies the facts section of an earlier ruling and incorporates the rest of that ruling by reference. The revised facts describe a foreign corporation owned by…
Company in liquidation gets 120 days to file a corporate classification election
A state court placed a limited liability company into liquidation and appointed a receiver whose deputy took control of the company's assets and operations. The deputy relied on a tax professional who…
Late relief to elect corporate tax classification for a single-member LLC
A single-member LLC wanted to be taxed as a corporation from the day it was formed, but it never filed the required Form 8832 entity classification election on time. By default a single-owner LLC is d…
Late relief for a foreign entity to elect disregarded status
A foreign company wholly owned by a single owner wanted to be treated as a disregarded entity (ignored as separate from its owner) for U.S. federal tax purposes, effective from a specific date. By ina…
IRS grants a foreign entity more time to elect corporate classification
A foreign eligible entity intended to change from partnership classification to an association taxable as a corporation, but it did not file Form 8832 on time because of inadvertence. The entity repre…
IRS permits a foreign entity to change to disregarded status within 60 months
A foreign eligible entity had elected to be taxed as a corporation and later wanted to change its classification to a disregarded entity. Normally, an entity cannot make another classification electio…
Late-election relief for a foreign entity to switch from corporation to disregarded status
A single-owner foreign entity whose members all had limited liability defaulted to being treated as an association taxable as a corporation for U.S. federal tax purposes. The owner intended for it to …
Late-election relief for a foreign entity to be a disregarded entity
A foreign entity with a single owner was eligible to elect to be disregarded (ignored as separate from its owner) for U.S. federal tax purposes, but it missed the deadline to file Form 8832 making tha…
Late-election relief for an LLC to be taxed as a corporation and opt out of tax-exempt-use rules
A single-member LLC, wholly owned by a § 501(c)(3) tax-exempt organization, was the co-general partner in a partnership that developed a low-income housing tax credit property for the elderly. Because…
IRS consents to an early entity-classification change after an ownership shift
A limited liability company started out with a single owner, so by default it was a "disregarded entity" (ignored for tax, its income reported by the owner). It then elected to be taxed as an S corpor…
IRS consents to an early entity-classification change after an ownership shift
A limited liability company started out with a single owner, so by default it was a "disregarded entity" (ignored for tax, its income reported by the owner). It then elected to be taxed as an S corpor…
IRS consents to an early entity-classification change after an ownership shift
A limited liability company started out with a single owner, so by default it was a "disregarded entity" (ignored for tax, its income reported by the owner). It then elected to be taxed as an S corpor…
IRS consents to an early entity-classification change after an ownership shift
A limited liability company started out with a single owner, so by default it was a "disregarded entity" (ignored for tax, its income reported by the owner). It then elected to be taxed as an S corpor…
IRS grants a foreign entity extra time to file a late "check-the-box" election to be a disregarded entity
Under the "check-the-box" rules, an eligible business entity chooses how it is taxed by filing Form 8832; a foreign entity with a single owner can elect to be "disregarded," meaning it is treated as a…
State retiree-benefit trust has excluded income and no annual return requirement
A state agency created a trust to fund health and welfare benefits for retired state employees, their spouses, and dependents. Only the agency may designate contributions, and trust assets may be used…
Foreign corporation receives time to elect disregarded-entity status
A foreign private limited corporation was wholly owned by a foreign revocable grantor trust whose settlor and primary beneficiary had become a U.S. citizen. The corporation was eligible to elect disre…
Extending a bankruptcy liquidating trust's term won't cost it liquidating-trust status
A trust was created under a confirmed Chapter 11 bankruptcy plan to liquidate a debtor's assets, turn them into cash, resolve claims, and distribute the proceeds to beneficiaries. A trust set up this …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect partnership classification (late Form 8832 relief)
A foreign business entity, majority-owned by a foreign partnership, was eligible to elect to be treated as a partnership for U.S. federal tax purposes, but it missed the deadline to file the required …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect partnership classification (late Form 8832 relief)
A foreign business entity, majority-owned by a foreign partnership, was eligible to elect to be treated as a partnership for U.S. federal tax purposes, but it missed the deadline to file the required …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect partnership classification (late Form 8832 relief)
A foreign business entity, majority-owned by a foreign partnership, was eligible to elect to be treated as a partnership for U.S. federal tax purposes, but it missed the deadline to file the required …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity extra time to elect disregarded-entity status (late Form 8832 relief)
A foreign business entity, wholly owned by a foreign partnership, was eligible to elect to be treated as a "disregarded entity" (ignored as separate from its owner) for U.S. federal tax purposes, but …
IRS grants a foreign entity 120 days to make a late disregarded-entity election
A foreign eligible entity wholly owned by a foreign partnership intended to be disregarded for U.S. federal tax purposes from its formation date but failed to timely file Form 8832. It requested relie…
IRS grants a foreign entity 120 days to make a late partnership-classification election
A foreign eligible entity owned primarily by a foreign partnership intended to be classified as a partnership for U.S. federal tax purposes from its formation date but failed to timely file Form 8832.…
IRS grants a foreign entity 120 days to make a late disregarded-entity election
A foreign eligible entity wholly owned by a foreign partnership intended to be disregarded for U.S. federal tax purposes from its formation date but failed to timely file Form 8832. It requested relie…
IRS grants a foreign entity 120 days to make a late disregarded-entity election
A foreign eligible entity wholly owned by a foreign partnership intended to be disregarded for U.S. federal tax purposes from its formation date but failed to timely file Form 8832. It requested relie…
IRS grants a foreign entity 120 days to make a late disregarded-entity election
A foreign eligible entity wholly owned by a foreign partnership intended to be disregarded for U.S. federal tax purposes from its formation date but failed to timely file Form 8832. It requested relie…
IRS gives a limited partnership 120 days to make a late corporate election
A domestic limited partnership intended to be classified as an association taxable as a corporation from a specified effective date. It failed to timely file Form 8832 and requested an extension under…
IRS gives a limited partnership 120 days to make a late corporate election
A domestic limited partnership intended to be classified as an association taxable as a corporation from a specified effective date. It failed to timely file Form 8832 and requested an extension under…
IRS permits an LLC to change from corporate to partnership status within 60 months
An LLC had elected to change from disregarded-entity status to an association taxable as a corporation. Before 60 months had passed, a corporation acquired more than half of the LLC's ownership intere…
IRS allows F reorganization treatment after an invalid interstate domestication
A corporation attempted to domesticate from one state to another and dissolved in its original state. It later discovered that the original state's law did not permit the domestication, leaving it uni…
IRS grants 120 days for a late corporate-classification election
A domestic limited liability company intended to be treated as a corporation for federal tax purposes from a specified date. Because of inadvertence, it did not timely file Form 8832 making the entity…
IRS grants a foreign entity 120 days for a late corporate-classification election
A foreign eligible entity intended to elect corporate treatment for U.S. federal tax purposes from a specified date but inadvertently failed to file Form 8832 on time. The IRS concluded that the entit…
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.