District of Columbia Internal Revenue Service Ruling Letter
Description
How to fill out Internal Revenue Service Ruling Letter?
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FAQ
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.
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.
Second, PLRs are expensive. As of July 1, 2022, the filing fee for requesting a PLR increased from $10,000 to $12,500. And, an attorney or tax expert will charge thousands of dollars more to do the actual filing for you. Lastly, there's no guarantee that the IRS will rule in your favor.
The IRS clarified the nature of franchise advertising fees in Private Letter Ruling 9834003, which states that contributions toward operations within an ad fund that violate the limited purpose are taxable as gross income.
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.
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).
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.