IRS Written Determinations

IRS Written Determination on Qualified Opportunity Fund Election Extensions

The IRS has issued a written determination granting relief under sections 301.9100-1 and 301.9100-3 for a taxpayer's late election to self-certify as a Qualified Opportunity Fund. The determination addresses the specific facts of a limited liability company that failed to file Form 8996 due to a misunderstanding of reporting requirements.

IRS Ruling on Inadvertent S Corporation Election Termination

The IRS has issued a written determination addressing an inadvertent termination of an S corporation election due to late Qualified Subchapter S Trust (QSST) elections. The ruling grants relief under Section 1362(f), allowing the corporation to retain its S corporation status.

IRS Written Determination on S Corporation Reorganization and Equity Grants

The IRS has released a written determination (PLR-112688-25) addressing a corporate reorganization involving an S corporation and subsequent equity grants to employees. The determination clarifies the tax treatment of these transactions, particularly concerning the S corporation status and the issuance of shares under employee compensation plans.

IRS Written Determination on Portability Election Extension

The IRS has issued a written determination granting an extension of time for a decedent's estate to make a portability election. This election allows a surviving spouse to utilize the deceased spouse's unused exclusion amount for estate tax purposes. The determination addresses the specific circumstances under which such an extension was granted.

IRS Written Determination: Extension for Entity Classification Election

The IRS has released a written determination granting an extension of time for a foreign eligible entity to file an election to be treated as a disregarded entity for U.S. federal income tax purposes. This determination addresses the application of § 301.9100-3 for late entity classification elections.

IRS Written Determination: Extension of Time for Tax Elections

The IRS has issued Written Determination 202612008, granting an extension of time for a taxpayer to make a regulatory election to adopt a specific taxable year. The determination addresses the criteria for relief under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations.

IRS Denies Tax Exemption for 501(c)(4) Organization

The IRS has issued a final determination denying tax-exempt status to a 501(c)(4) organization. The organization failed to file a protest within the 30-day period following a proposed adverse determination. The IRS cited the organization's operations as a real estate management association funded similarly to a homeowners' association as the basis for denial.

IRS Denies Tax Exemption Under IRC Section 501(c)(3)

The IRS has issued a final determination denying tax-exempt status to an organization under IRC Section 501(c)(3). The organization failed to submit a protest within the 30-day period following a proposed adverse determination. As a result, donors cannot deduct contributions, and the organization must file federal income tax forms.

IRS Approval of Scholarship Procedures Under IRC Section 4945(g)(1)

The IRS has approved the scholarship procedures of a private foundation under IRC Section 4945(g)(1). This determination means that grants made under these approved procedures will not be considered taxable expenditures for the foundation and may not be taxable to the recipients if used for qualified educational expenses.

IRS Written Determination: Extension for Entity Classification Election

The IRS has released a written determination granting an extension of time for an entity (X) to file Form 8832, Entity Classification Election. The entity inadvertently failed to timely elect to be classified as an association taxable as a corporation for federal tax purposes.