Get Appendix A Sample Format for a Letter Ruling Request

A private letter ruling (PLR) is a written decision by the Internal Revenue Service (IRS), in response to a taxpayer's request for guidance on unusual circumstances or complex questions about their specific tax situation.

Letter rulings are made public, but confidential information is redacted. Rulings can be expensive: 2013 fees, for instance, range from $150 for simple requests to $50,000 for pre-filing agreements. A ruling for a specific transaction costs $18,000, but typically ranges up to $30,000.

The IRS generally attempts to process the ruling request within 60 90 days. If multiple branches of the IRS need to review the ruling or other extenuating circumstances exist, the ruling process can take more than 6 months.

A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's represented set of facts. A PLR is issued in response to a written request submitted by a taxpayer. A PLR may not be relied on as precedent by other taxpayers or by IRS personnel.

All private letter rulings are published and are accessible by the general public. However, all taxpayer identifying information is deleted to ensure the privacy of the requesting taxpayer.

A Revenue Procedure is an official statement of a procedure that affects the rights or duties of taxpayers under the law, while a Revenue Ruling is the conclusion of the IRS on how the law is applied to a specific set of facts.

The IRS generally attempts to process the ruling request within 60 90 days. If multiple branches of the IRS need to review the ruling or other extenuating circumstances exist, the ruling process can take more than 6 months.

The range is from $250 - $50,000. That's right, there is a $49,750 variance in Private Letter Ruling fees depending on what type of Private Letter Ruling you are seeking.

A private letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated), but only those parties. Thus, a private ruling may not be cited or relied upon as precedent by other taxpayers.

Ruling Request means any letter filed by Parent with the IRS or other Tax Authority requesting a ruling regarding certain tax consequences of any of the Separation Transactions (including all attachments, exhibits, and other materials submitted with such ruling request letter) and any amendments or supplements to such ...

A private letter ruling (PLR) is a written decision by the Internal Revenue Service (IRS), in response to a taxpayer's request for guidance on unusual circumstances or complex questions about their specific tax situation.

Private letter ruling. Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance. ... PLRs from 1997, forward, are available to the public through the IRS Electronic reading room. (see 26 U.S.C. § 6110).

A Private Letter Ruling is a written statement issued to a taxpayer by the national office of the IRS that interprets and applies the tax laws to the taxpayer's specific set of proposed facts. ... Private Letter Rulings are not officially published in a reporter.

A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's represented set of facts. A PLR is issued in response to a written request submitted by a taxpayer. A PLR may not be relied on as precedent by other taxpayers or by IRS personnel.

The IRS generally attempts to process the ruling request within 60 90 days. If multiple branches of the IRS need to review the ruling or other extenuating circumstances exist, the ruling process can take more than 6 months.