Get Announcement 2004-8 - Correction Of User Fee In Appendix A Of Rev. Proc. 2004-1. This Announcement

A determination letter is similar in purpose and nature to a private letter ruling, except that it is issued by the office of the local IRS district director not the national office of the IRS.

Private Letter Ruling A PLR may not be relied on as precedent by other taxpayers or IRS personnel. PLRs are generally made public after all information has been removed that could identify the taxpayer to whom it was issued.

Where fast-track handling is available, the IRS will endeavor to issue a private letter ruling in a compressed time frame, generally about 12 weeks. Outside of the fast-track process, the IRS generally aims to respond to ruling requests within 180 days of receipt, though more complex issues can take more time.

Fees incurred by the taxpayer can range from $150 for simple requests to $50,000 for pre-filing agreements. For a specific transaction, a ruling can cost as much as $30,000, in addition to the professional fees that a taxpayer may incur.

For most of our ruling requests, the user fee for 2023 is $38,000. If the taxpayer meets certain income qualifications, that rate can be reduced.

Rev. Proc. 2023-1 retains 2022 user fees (typically, $38,000 for private letter ruling requests; reduced fees of $3,000 and $8,500 for certain “small” organizations).

No user fee is required for a Form 3115 filed under the automatic change procedures. An applicant that timely files and complies with the automatic change procedures is granted consent to change its accounting method, subject to review by the IRS National Office and operating division director.

01 Rev. Rul. 2004-86, 2004-2 C.B. 191, holds that a Delaware statutory trust (Trust) formed to hold real property subject to a lease under the trust agreement described in the ruling is an arrangement that is classified as a trust for Federal tax purposes under § 301.7701-4(c).