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Taxpayers requesting a private letter ruling should consult the Revenue Procedure published by the IRS at the start of each calendar year, which describes guidelines and updates for the process and includes sample request letter templates and a checklist of over 50 questions that must be answered.
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 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.
EIN'S beginning with the number 98 may identify foreign entities that maintain domestic trusts in the United States. Methods to accurately identify domestic trusts maintained by foreign entities are being reviewed, as well as general information about the trust and any other domestic trusts you may maintain.
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).
On 27 July 2023, the IRS issued Rev. Proc. 2023-26, creating a permanent fast-track process for private letter ruling (PLR) requests solely or primarily under the jurisdiction of Associate Chief Counsel (Corporate).
§1462. Withheld tax as credit to recipient of income. Income on which any tax is required to be withheld at the source under this chapter shall be included in the return of the recipient of such income, but any amount of tax so withheld shall be credited against the amount of income tax as computed in such return.
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). Rev. Proc. 3 does not contain new ?no rule? areas specific to exempt organizations.