Ellen McElroy

Eversheds Sutherland (US) LLP

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Latest Posts › Private Letter Rulings

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A fickle friend: Released on the same day, IRS rulings grant and deny 9100 relief

On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more

12/27/2023 / Accounting Methods , Filing Deadlines , Income Taxes , IRS , Private Letter Rulings , Tax Liability , Tax Planning , Time Extensions

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor

The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more

10/17/2017 / IRS , Private Letter Rulings , Safe Harbors , Tax Relief

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

3/30/2017 / Auto Parts , Bonus Depreciation , Corporate Restructuring , Corporate Taxes , Intangible Property , IRS , Net Operating Losses , Private Letter Rulings

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