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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IRS consents to an early entity-classification change after an ownership shift
A foreign eligible entity originally elected to be disregarded and later elected association status taxable as a corporation. It then underwent a change of more than 50 percent in ownership and sought…
IRS permits a foreign entity's early return to disregarded status
A foreign eligible entity initially elected to be disregarded and later changed its classification to an association taxable as a corporation. After a greater-than-50-percent change in ownership, it a…
Ownership change permits an early return to disregarded status
A foreign eligible entity first elected disregarded status and later elected to be an association taxable as a corporation. It then experienced a change of more than 50 percent in ownership and reques…
IRS consents to another early disregarded-entity election
A foreign eligible entity had elected disregarded status, subsequently elected association status taxable as a corporation, and then underwent a greater-than-50-percent ownership change. It requested …
IRS allows an early check-the-box change after new ownership
A foreign eligible entity had previously changed from disregarded status to association status taxable as a corporation. More than half of its ownership then changed, and it sought consent to elect di…
Foreign entity receives 120 days to file a late classification election
A foreign eligible entity intended to elect disregarded-entity status for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS concluded that the entity satisfied the stand…
Foreign entity receives 120 days to elect disregarded status
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status with its requested effective date. The IRS found that the entity met the standards in Treas. Reg. §§ 301.9…
Foreign entity receives 120 days to elect disregarded status
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status with its requested effective date. The IRS found that the entity met the standards in Treas. Reg. §§ 301.9…
LLC receives 120 days to make a late corporate classification election
A limited liability company intended from its formation to be classified as an association taxable as a corporation for federal tax purposes. It did not timely file Form 8832 to make that entity-class…
Foreign entity receives 120 days to make a late disregarded-entity election
A foreign entity wholly owned by a U.S. citizen was formed to hold interests in another entity. It became relevant for U.S. tax purposes on a redacted date and intended to be classified as disregarded…
Foreign entity receives 120 days to make a late partnership election
A foreign entity owned by a U.S. citizen and another investor was formed to hold interests in another entity. It became relevant for U.S. tax purposes on a redacted date and intended to be classified …
Foreign entity receives late disregarded-entity election relief
A foreign entity intended to elect disregarded-entity treatment but did not timely file Form 8832. It represented that it was eligible for the election, acted reasonably and in good faith, did not use…
LLC receives 120 days to file a corporate classification election
A domestic limited liability company intended to be classified as an association taxable as a corporation from a specified date. It failed to file Form 8832 within the normal election period and reque…
Foreign entity received 120 days for late Form 8832
A foreign eligible entity intended to elect disregarded-entity status but did not timely file Form 8832. It represented that it acted reasonably and in good faith and that relief would not prejudice t…
Foreign entity received late disregarded-entity election relief
A foreign eligible entity failed to timely file Form 8832 electing disregarded-entity status from the date it was organized. It represented that it acted reasonably and in good faith and that relief w…
LLC gets 120 days to elect partnership classification
A multi-member limited liability company had initially elected corporate classification for federal tax purposes. It later intended to be treated as a partnership from a specified effective date but f…
IRS grants foreign entity late disregarded-entity election
A foreign eligible entity wholly owned by a domestic partnership inadvertently failed to file Form 8832 electing disregarded-entity status from its formation date. The IRS granted 120 days to file the…
Two-year extension preserves bankruptcy liquidating-trust status
A trust created under a Chapter 11 bankruptcy plan held and pursued litigation claims for the benefit of creditors and distributed liquidation proceeds. Its original five-year term had already been ex…
Foreign entity receives extra time for disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its owner for federal tax purposes, but Form 8832 was not timely filed. The IRS concluded that the entity acted reasonably and in g…
Late Form 8832 allowed for foreign disregarded entity
A foreign eligible entity intended to elect disregarded-entity status but did not timely file Form 8832. The IRS found that the requirements for discretionary filing relief were met and granted a 120-…
IRS grants late disregarded-entity classification election
A foreign eligible entity intended to be classified as disregarded from its single owner, but it inadvertently missed the Form 8832 filing deadline. The IRS granted a 120-day extension to make the ele…
Foreign company may file late disregarded-entity election
A foreign eligible entity intended to be disregarded as separate from its owner but failed to file Form 8832 on time. The IRS determined that the entity qualified for discretionary election relief and…
Filing extension granted for foreign entity classification election
A foreign eligible entity wanted disregarded-entity treatment effective from a specified date but inadvertently failed to file Form 8832. The IRS granted 120 days to submit the late election. The reli…
Filing extension granted for foreign entity classification election
A foreign eligible entity wanted disregarded-entity treatment effective from a specified date but inadvertently failed to file Form 8832. The IRS granted 120 days to submit the late election. The reli…
Filing extension granted for foreign entity classification election
A foreign eligible entity wanted disregarded-entity treatment effective from a specified date but inadvertently failed to file Form 8832. The IRS granted 120 days to submit the late election. The reli…
Foreign entity gets late relief to elect partnership treatment on Form 8832
A foreign business entity eligible to choose its U.S. federal tax classification wanted to be treated as a partnership but failed to file Form 8832 (the "check-the-box" election) on time. Without the …
Foreign entity gets late relief to elect partnership treatment on Form 8832
A foreign business entity eligible to choose its U.S. federal tax classification wanted to be treated as a partnership but failed to file Form 8832 (the "check-the-box" election) on time. Without the …
Foreign entity gets late relief to elect partnership treatment on Form 8832
A foreign business entity that was eligible to choose how it is classified for U.S. federal tax purposes wanted to be treated as a partnership, but failed to file Form 8832 (the "check-the-box" entity…
Late disregarded-entity election approved before automatic partnership classification
A domestic limited liability company began with one member and later added members. It intended to be disregarded as separate from its owner from formation and then treated as a partnership when the a…
Foreign entity receives 120 days to make a late disregarded-entity election
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status from its intended effective date. The IRS found that the entity satisfied the standards for regulatory-ele…
Foreign entity receives 120 days to make a late disregarded-entity election
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status from its formation date. The IRS found that the entity satisfied the standards for regulatory-election rel…
Foreign entity receives 120 days to make a late partnership election
A foreign eligible entity failed to file Form 8832 on time to elect partnership status from its formation date. The IRS found that the entity satisfied the standards for regulatory-election relief and…
Foreign entity receives 120 days to make a late disregarded-entity election
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status from its formation date. The IRS found that the entity satisfied the standards for regulatory-election rel…
Foreign entity receives 120 days to make a late disregarded-entity election
A foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status from its formation date. The IRS found that the entity satisfied the standards for regulatory-election rel…
Foreign entity received 120 days to file late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its formation date but did not timely file Form 8832. It represented that the omission occurred despite reasonable, good-faith cond…
Foreign entity received 120 days to file late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its formation date but did not timely file Form 8832. It represented that the omission occurred despite reasonable, good-faith cond…
Foreign entity received 120 days to file late disregarded-entity election
A foreign eligible entity intended to be treated as disregarded from its formation date but did not timely file Form 8832. It represented that the omission occurred despite reasonable, good-faith cond…
Bankruptcy trust remains a liquidating trust during another extension
A trust was created under a Chapter 11 liquidation plan to sell assets and distribute the proceeds to beneficiaries. Its agreement prohibited operating a trade or business, limited retained cash, requ…
Foreign entity gets 120 days for a late corporate-classification election
A foreign eligible entity had filed an erroneous election to be treated as a partnership and sought to elect corporate tax status effective on the same redacted date. The entity represented that it ac…
Foreign entity gets 120 days for a late disregarded-entity election
A single-owner foreign eligible entity was classified by default as a corporation because its owner had limited liability. During a reorganization, the entity transferred its assets and liabilities to…
Foreign entity receives 120-day extension for corporate classification election
A foreign eligible entity failed to timely file Form 8832 to be treated as an association taxable as a corporation from its requested effective date. It represented that it acted reasonably and in goo…
Foreign company receives 120-day extension for partnership classification election
A foreign eligible entity with multiple owners had a default classification as an association taxable as a corporation. It intended to elect partnership treatment but relied on a tax professional who …
Foreign company receives 120-day extension for partnership classification election
A foreign eligible entity with multiple owners had a default classification as an association taxable as a corporation. It intended to elect partnership treatment but relied on a tax professional who …
Foreign entity may change classification within the 60-month limit
A foreign eligible entity had changed from its default corporate classification to disregarded-entity status. It later underwent a change in ownership of more than 50 percent and wanted to elect corpo…
Foreign LLC gets 120 days for retroactive disregarded status
A foreign limited liability company intended to elect disregarded-entity classification effective from its formation date but did not timely file Form 8832. Its ownership later changed from two U.S. p…
LLC received inadvertent S corporation election relief after fixing its operating agreement
A limited liability company elected S corporation status, but its operating agreement contained partnership provisions that created more than one class of stock. The members later amended the agreemen…
LLC received 120 days to make a late partnership classification election
A limited liability company intended to be treated as a partnership for federal tax purposes from a specified date. It did not file Form 8832, the entity classification election, on time. The IRS conc…
Multi-member LLC received 120 days to file a late corporate classification election
A limited liability company with 22 members intended to be classified as an association taxable as a corporation from its formation date. It missed the deadline for filing Form 8832, but neither the c…
Two foreign LLCs received 120 days for late partnership elections
Two foreign limited liability companies intended to be classified as partnerships from their respective formation dates but did not timely file Forms 8832. Because all members of a foreign eligible en…
Further term extension preserves bankruptcy liquidating trust status
A liquidating trust was created under a confirmed Chapter 11 plan to sell assets and distribute the proceeds to beneficiaries. Its agreement prohibited an ongoing business, limited retained cash to am…
Foreign entity received 120 days for a late disregarded-entity election
A foreign single-owner entity intended to be disregarded for U.S. federal tax purposes from its formation date. It was owned by a domestic disregarded entity, which in turn was owned by an S corporati…
Foreign entity received extension to elect disregarded status
A foreign entity intended to be classified as a disregarded entity but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied the requirements for discretionary electi…
Foreign entity received 120 days for late disregarded-entity election
A foreign eligible entity intended to be treated as a disregarded entity from a specified date but inadvertently failed to file Form 8832 on time. The IRS found that the requirements for discretionary…
Three-year trust extension did not disturb liquidating trust classification
A trust was created under a Chapter 11 liquidation plan solely to liquidate and distribute transferred assets, without continuing a trade or business. The bankruptcy court had already extended its ori…
Foreign entity received 120 days for late disregarded-entity election
A foreign eligible entity intended to elect disregarded-entity treatment from a specified date but inadvertently failed to file Form 8832 on time. The IRS found that the requirements for discretionary…
Foreign entity received 120 days for a late disregarded-entity election
A wholly owned foreign eligible entity intended to be classified as disregarded for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the regulatory-extension…
LLC received 120 days to correct a mistaken corporate election
A domestic single-member limited liability company intended to be disregarded for federal tax purposes and filed returns consistently with that treatment. It mistakenly submitted Form 8832 electing as…
Entity received 120 days for a late corporate classification election
An eligible entity intended to be classified as an association taxable as a corporation but inadvertently failed to file Form 8832 on time. It represented that its federal returns were consistent with…
Foreign entity received 120 days for a late partnership election
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but failed to file Form 8832 on time. It represented that the failure was not motivated by tax avoidance o…
Foreign entity received 120 days for a late disregarded-entity election
A foreign single-owner eligible entity intended to be disregarded for federal tax purposes from its formation date but failed to file Form 8832 on time. The IRS concluded that the regulatory-extension…
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.