A multinational taxpayer successfully persuaded the IRS Chief Counsel to retroactively alter its cost allocation method for controlled services transactions under the Comparable Profits Method (CPM), a change approved as a valid setoff under Treas. Reg. 482-1(g)(4).
S. investments from taxation when earned by foreign governments. The ruling addressed the Institution’s request to confirm that its accident insurance operations, medical clinic management, and workplace safety guidance did not constitute commercial activities under Section 892. S.
The IRS granted a taxpayer’s request to partially revoke a net capital gain election under Section 163(d)(4)(B), which permits taxpayers to include net capital gain in investment income for purposes of calculating deductible investment interest expense.
9100-3 to a taxpayer seeking to file a late §336(e) election, allowing the deemed asset sale treatment for a stock disposition of an S corporation. The relief hinged on the taxpayer’s demonstration of reasonable action and good faith, with no prejudice to the government.
The IRS granted a 45-day extension to a corporation and its subsidiaries after a CPA inadvertently failed to upload two original Forms 3115 to the taxpayer’s timely filed consolidated federal income tax return.
The IRS has issued a private letter ruling (PLR-114550-25) confirming that an estate may deduct income distributions to charitable organizations under Section 642(c)(1) of the Internal Revenue Code, provided the distributed amounts are includible in the estate’s gross income.
The IRS concluded in a recent private letter ruling (PLR-112870-25) that periodic payments under an indexed structured settlement annuity contract qualify as "fixed and determinable" under § 130(c)(2)(A) and that the annuity qualifies as a "qualified funding asset" under §...
The IRS granted relief under § 1362(f) to an S corporation whose status terminated after trusts holding its shares failed to make timely Qualified Subchapter S Trust (QSST) elections under § 1361(d).
2642-7 to a taxpayer seeking to retroactively allocate Generation-Skipping Transfer (GST) exemption to transfers made in Year 1. The relief permits the taxpayer to file a supplemental Form 709 to correct the omission, avoiding potential GST tax liability on future distributions to skip persons.
The IRS granted a 60-day extension under Treas. Reg. 9100-3 to a real estate partnership for a late § 163(j)(7)(B) election, allowing it to opt out of the 30% business interest deduction limitation for its Year 2 taxable year.
A taxpayer narrowly avoided a multimillion-dollar tax liability when the IRS granted a 60-day extension to file a late election to treat its business as a real property trade or business (RPTOB).
The IRS has clarified that small corporations failing to file Form 5472 or maintain records under Section 6038A may qualify for "liberal" application of reasonable cause relief, potentially avoiding a $25,000 penalty per violation.
S. tax purposes. The taxpayer’s election statement, prepared by qualified tax professionals, was never acknowledged by the IRS despite being filed in accordance with procedural rules.
9100-3 to a taxpayer who missed the deadline for making a § 168(k)(7) election to opt out of bonus depreciation. The taxpayer’s request stemmed from a preparer’s oversight—specifically, the failure to attach the required election statement to the original return.
9100-3 to a taxpayer who missed the deadline to file Form 8996, the self-certification election for a Qualified Opportunity Fund (QOF).
9100-3 to a taxpayer that missed the deadline to file Form 8996, the self-certification election for Qualified Opportunity Funds (QOFs). The taxpayer sought relief after failing to timely file the form due to reasonable reliance on a tax advisor, demonstrating that it acted in good faith.
The IRS has granted relief under Section 1362(f) to a taxpayer whose S corporation election terminated after a trust failed to file a required Qualified Subchapter S Trust (QSST) election, potentially exposing the corporation to retroactive tax liability.
The IRS granted § 1362(f) inadvertent termination relief to X, an S corporation, after Trust 2 failed to make a QSST election (§ 1361(d)) upon acquiring X stock.
" The omission, attributed to the tax preparer’s oversight, risked requiring the taxpayer to use the Alternative Depreciation System (ADS) for its partnership assets, potentially resulting in significant lost depreciation deductions. 9100-3 to correct the error.
The IRS granted a 120-day extension to an LLC that missed the deadline to file Form 8832, the entity classification election, due to an inadvertent failure to submit the form. 9100-3, which permits extensions for regulatory elections when the taxpayer acts reasonably and in good faith.
9100-3—which provides relief for late regulatory elections—to two entities (X and Y) to file Form 8832 for entity classification elections. The IRS approved a 120-day extension for both entities to elect partnership and disregarded entity status, respectively, effective Date 2.
The IRS ruled in a non-precedential Private Letter Ruling (PLR) dated April 2026 that a regulated public utility’s assets do not qualify as public utility property under § 168(i)(9), which defines property used by utilities subject to normalization rules.
The IRS ruled that bonds financing a state-formed political subdivision’s advanced water purification project would not meet the private business use tests under § 141(b), resolving concerns that contracts with privately owned water utilities might jeopardize tax-exempt status.
The Tax Court’s April 22 ruling in Cathryn A. Simmons v. Commissioner delivered a harsh lesson in the unforgiving nature of tax substantiation rules, costing a boutique owner and landlord $80,536 in additional tax for 2017, a $16,107 accuracy-related penalty, and $4,219 for 2019.
In Marie Kanda v. C. Memo. 2026-XX), the Tax Court addressed whether Marie M. Kanda, who filed pro se, qualified for COVID-19-related credits after the IRS issued a $26,560 deficiency notice for tax year 2022.
9100-3 to an estate that missed the portability election deadline under § 2010(c)(5)(A), allowing the surviving spouse to claim the deceased spousal unused exclusion (DSUE) amount.
The IRS ruled that a proposed spin-off and merger qualified as tax-free under Section 355—which governs tax-free corporate spin-offs—and Section 368—which defines tax-free reorganizations—according to a private letter ruling issued in April 2026.
9100-3 of the Procedure and Administration Regulations. The taxpayers had missed the filing deadline for their intended corporate elections but demonstrated they acted in good faith and that granting relief would not prejudice the government’s interests.
The IRS granted a 75-day extension to an S corporation that missed the deadline to file a § 336(e) election for a $X million stock sale, treating the transaction as an asset sale for tax purposes.
The IRS granted § 9100-1 relief to a taxpayer who requested an extension of time to file Form 8996—the self-certification form for Qualified Opportunity Funds (QOFs)—after missing the deadline.