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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120-day extension to make a late § 754 partnership basis-adjustment election
A partnership can elect under § 754 to adjust the tax basis of its assets when a partnership interest changes hands (including on a partner's death) or when it distributes property. That adjustment le…
120-day extension to make a late § 754 partnership basis-adjustment election
A partnership can elect under § 754 to adjust the tax basis of its assets when a partnership interest is transferred or when it distributes property. The adjustment lets the affected partner's share o…
A limited partner's conditional deficit-restoration obligation is not a payment obligation under § 1.752-2(b)
The IRS Office of Chief Counsel advised on how partnership debt is allocated among partners. When a partner "bears the economic risk of loss" for a partnership liability, that debt is treated as recou…
§ 9100 extension to make a late § 754 election to adjust partnership basis
A partnership can elect under IRC § 754 to adjust the tax basis of its assets when a partner's interest changes hands or when property is distributed, so the inside basis better matches what the partn…
120-day extension to make a late § 754 partnership basis-adjustment election
A state limited partnership meant to make a § 754 election but missed the deadline. A § 754 election lets a partnership adjust the tax basis of its assets when a partner's interest transfers (here, a …
9100 extension to make a late § 754 election after a partner's death
A limited liability company taxed as a partnership had one of its partners die. When a partnership interest transfers (including at death), the partnership's basis in its own assets (inside basis) can…
9100 extension to make a late § 754 election after a partner's death
A limited liability company taxed as a partnership had a partner die. A partner's death transfers the partnership interest, which can leave the partnership's basis in its assets (inside basis) out of …
9100 extension to make a late § 754 election after a partner's death
A limited liability company taxed as a partnership had a partner die. A partner's death transfers the partnership interest, which can leave the partnership's basis in its assets (inside basis) out of …
Tax-free contribution of already-diversified securities portfolios to an investment-company partnership under 721
When someone contributes property to a partnership in exchange for a partnership interest, section 721 usually lets them do it without paying tax on any built-in gain. There is an exception in section…
9100 relief for a late section 754 partnership basis-adjustment election
A partnership (an LLC taxed as a partnership) forgot to make a Section 754 election. That election lets a partnership adjust the tax basis of its assets when a partner's interest changes hands or prop…
120-day extension to make a late section 754 election after a partner died
A limited partnership had a partner die. When a partnership interest transfers (including at death), a section 754 election lets the partnership adjust the tax basis of its property so the new owner's…
120 days granted to make a late Section 754 basis-adjustment election after a partner's death
An LLC treated as a partnership for tax purposes had a partner die during the year. When a partner dies (or a partnership interest otherwise transfers), a Section 754 election lets the partnership adj…
120 days granted to make a late Section 754 basis-adjustment election, via an amended partnership return
An LLC taxed as a partnership meant to make a Section 754 election, which lets a partnership adjust the tax basis of its property when interests change hands or property is distributed, but it missed …
120 days granted to make a late Section 754 basis-adjustment election, via an amended partnership return
An LLC taxed as a partnership meant to make a Section 754 election, which lets a partnership adjust the tax basis of its property when interests change hands or property is distributed, but it missed …
IRS grants a partnership extra time to make a late § 754 basis-adjustment election
A limited partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its property when a partner transfers an interest or receives a distribution. That adjustm…
Late § 754 election allowed for a partnership after two partners died
A partnership missed the deadline to make a § 754 election and asked the IRS for more time. A § 754 election lets a partnership adjust the tax basis of its assets when a partner's interest changes han…
Late § 754 election allowed for an LLC taxed as a partnership
An LLC taxed as a partnership meant to make a § 754 election but did not file it on time with its return. A § 754 election lets a partnership adjust the tax basis of its assets when interests change h…
120-day extension for a partnership to make a late § 754 basis-adjustment election
An LLC taxed as a partnership wanted to make a § 754 election, which lets a partnership adjust the tax basis of its assets when a partner's interest changes hands or property is distributed, so the ne…
120-day extension for a partnership to make a late § 754 basis-adjustment election
An LLC taxed as a partnership wanted to make a § 754 election, which lets a partnership adjust the tax basis of its assets when a partner's interest changes hands, so a buying partner's inside basis m…
120-day extension to file a late Section 754 election to adjust partnership property basis
A Section 754 election lets a partnership adjust the tax basis of its property when a partner's interest changes hands or property is distributed, so the new numbers line up with what partners actuall…
9100-3 relief granting 120 days to make a late section 754 election so a partnership can adjust the basis of its property after a partner's death
A partnership had a partner die, an event that (with a section 754 election in place) lets the partnership step up the inside basis of its assets to match the value the deceased partner's successor no…
120-day extension to make a late section 754 basis-adjustment election
A state limited liability company taxed as a partnership meant to make a section 754 election for a particular tax year but inadvertently failed to make it properly. A section 754 election lets a part…
120-day extension to make a late section 754 basis-adjustment election
A limited liability limited partnership had a partner die during a tax year. When a partnership interest transfers (including on a partner's death), a section 754 election lets the partnership adjust …
IRS grants an LLC partnership a 120-day extension to make a late Section 754 basis-adjustment election
An LLC taxed as a partnership wanted to make a Section 754 election, which lets a partnership adjust the tax basis of its assets when interests change hands or property is distributed, so the inside b…
IRS grants an LLC a late Section 754 election to adjust the basis of partnership property
An LLC taxed as a partnership meant to make a Section 754 election but its tax advisors inadvertently failed to file it on time. A Section 754 election lets a partnership adjust the inside tax basis o…
IRS grants an LLC a late Section 754 election to adjust the basis of partnership property
An LLC taxed as a partnership meant to make a Section 754 election but inadvertently missed it. A Section 754 election lets a partnership adjust the tax basis of its assets when interests change hands…
9100 extension to make a late section 754 partnership basis-adjustment election (754)
A limited liability company taxed as a partnership had a new buyer acquire interests in it. The partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its …
9100 extension to make a late section 754 partnership basis-adjustment election (754)
A limited liability company taxed as a partnership had a new buyer acquire interests in it. The partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its …
9100 extension to make a late section 754 partnership basis-adjustment election (754)
A limited liability company taxed as a partnership had a new buyer acquire interests in it. The partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its …
9100 extension to make a late section 754 partnership basis-adjustment election (754)
A limited liability company taxed as a partnership had a new buyer acquire interests in it. The partnership wanted to make a section 754 election, which lets a partnership adjust the tax basis of its …
IRS grants a partnership 120 days to make a late Section 754 election
A partnership intended to elect under IRC § 754 to adjust the basis of partnership property after one member bought additional interests from another member. It inadvertently omitted the election from…
IRS grants a partnership 120 days to make a late Section 754 election
A partnership failed to make an IRC § 754 election for the tax year in which one of its partners died. The election would permit adjustments to the basis of partnership property following a transfer o…
Partnership receives 120 days to make a late section 754 election
A partnership intended to make an IRC § 754 election for a prior tax year but failed to file it on time. The IRS concluded that the partnership satisfied the standards for discretionary relief under T…
Partnership receives 120 days to make late Section 754 election
A partnership failed to make an IRC § 754 election for the year in which one of its partners died. The election would permit basis adjustments under IRC §§ 734 and 743 for partnership property and tra…
Partnership received 120 days to make late section 754 election
A domestic limited liability company treated as a partnership sold ownership interests to a new buyer and intended to make an IRC § 754 election for that year. It inadvertently failed to attach a vali…
Reorganized partnership received 120 days to make late section 754 election
A limited liability company treated as a partnership reorganized under another state's law, after which two parties acquired interests in it. The partnership intended to make an IRC § 754 election for…
Partnership receives extension for late section 754 election
A partnership intended to elect under IRC § 754 to adjust the basis of partnership property but omitted the election from its timely filed return. The IRS concluded that the partnership satisfied the …
Partnership received 120 days to make late section 754 election
A partnership inadvertently omitted a § 754 election from its return for the year in which a buyer acquired partnership interests. The IRS found that the partnership satisfied the standards for regula…
Partnership received 120 days to make section 754 election after partner's death
A partner died during a partnership's taxable year, but the partnership inadvertently failed to make a valid § 754 election with that year's return. The IRS found that the partnership met the standard…
Partnership receives 120 days to make a late section 754 election
A general partnership intended to make an IRC § 754 election for a specified tax year but did not include the election with its timely partnership return. The IRS concluded that the partnership satisf…
Partnership receives 120 days to make a late section 754 election
A limited liability company taxed as a partnership failed to file an IRC § 754 election for the year in which an owner died holding an interest through a grantor trust. The partnership represented tha…
Partnership gets 120 days to make a late section 754 election
An existing partner bought additional interests in a limited liability company taxed as a partnership. The partnership timely filed its federal return for the year but inadvertently omitted its intend…
Partnership receives more time to make section 754 election
A limited liability company taxed as a partnership intended to make an IRC § 754 election after transactions that it represented were sales or exchanges of partnership interests, but it inadvertently …
Late partnership section 754 election approved
A limited liability company treated as a partnership failed to timely elect under IRC § 754 after a buyer purchased partnership interests in a transaction the company treated as a disguised sale. The …
Partnership received more time to make section 754 basis election
A partnership sold interests to new partners and intended to make an IRC § 754 election with its return but inadvertently failed to do so. The election would permit basis adjustments under IRC §§ 734 …
Lower-tier partnership received 120 days to make a section 754 election
A lower-tier partnership missed its section 754 election after a partner in an upper-tier partnership sold its interest. The upper-tier partnership had a section 754 election in effect, and the lower-…
Partnership received 120 days to make a late section 754 election
A partnership intended to make a section 754 election after an ownership change but failed to file the election on time. It requested discretionary late-election relief. The IRS concluded that the par…
Partnership received 120 days to make a section 754 election after a partner's death
A partnership failed to make a section 754 election for the tax year in which one of its partners died. It requested discretionary relief to make the election late. The IRS concluded that the partners…
Partnership received 120 days to make a late section 754 election
A limited partnership intended to elect under section 754 after a partner died, but it inadvertently omitted a valid election from its timely partnership return. The election would allow partnership p…
Partnership granted extension to make late section 754 election
A limited liability company treated as a partnership intended to make a section 754 election but inadvertently failed to attach a valid election to its timely partnership return. The IRS found that th…
Partnership received 120 days to make a late section 754 election
A partnership missed the deadline to make a section 754 election after one of its partners died. The IRS found that the partnership satisfied the standards for regulatory election relief and granted 1…
Partnership received 120 days to make a late section 754 election
A foreign limited partnership intended to make a section 754 election but inadvertently omitted the election from its timely partnership return. The IRS found that the partnership satisfied the regula…
Partnership received 120 days to make a late section 754 election
A limited liability company taxed as a partnership intended to make a section 754 election but failed to include it with its return. The IRS accepted the company's representations that it acted reason…
Partnership received 120 days to make a late section 754 election
A partnership had previously made a section 754 election, but a later ownership change caused a technical termination under the law then in effect. After another partner-interest purchase, the partner…
Prior section 754 election deadline extended by 60 days
The IRS had previously issued a private letter ruling concerning the taxpayer's deadline to file a section 754 election. This supplemental ruling does not restate the facts or analysis from the earlie…
IRS grants 120 days to make a late partnership basis election
A limited liability company taxed as a partnership missed the deadline to elect under IRC § 754 after a 50 percent general partner died. That election allows the partnership to adjust the basis of its…
Partnership receives 120 days to make a late § 754 election
A partnership missed the deadline to make a § 754 election for the year a partner died because its tax advisers did not adequately advise it about the election. The partnership represented that it act…
Partnership receives 120 days for a late § 754 election after an interest sale
A limited liability company taxed as a partnership engaged in a transaction that it represented was a sale of partnership interests for federal tax purposes. It inadvertently failed to make a § 754 el…
Partnership receives limited time to make a late § 754 election
A limited liability company taxed as a partnership intended to make a § 754 election but inadvertently failed to file a valid election with its partnership return. The IRS concluded that the partnersh…
Partnership receives 120 days to make a late section 754 election
A partnership failed to file a section 754 election for the tax year in which one of its partners died. That election allows partnership property basis adjustments following certain distributions or t…
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.