Wisconsin Internal Revenue Service Ruling Letter
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How to fill out Internal Revenue Service Ruling Letter?
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FAQ
A private letter ruling (PLR) is a written decision by the Internal Revenue Service (IRS) that is sent in response to a taxpayer's request for guidance on unusual circumstances or complex questions about their specific tax situation. For certain transactions involving large amounts of money, the tax law may be unclear.
A letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated) but only those parties, so the ruling may not be relied on as precedent by other taxpayers.
Similar to federal letter rulings, DOR Private Letter Rulings respond to a specific taxpayer's inquiry, and may shed light on how the DOR would approach a particular issue. Disputes between a taxpayer and the DOR are appealed to the Wisconsin Tax Appeals Commission (formerly Board of Tax Appeals).
For certain transactions involving large amounts of money, the tax law may be unclear. The purpose of the private letter ruling is to remove any uncertainty and to advise the taxpayer, usually a business, regarding the tax treatment they can expect from the IRS given the circumstances specified by their ruling.
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.
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.
10.2, Citing PLRs and TAMs ("Letter rulings and technical advice memorandums are cited PLR or TAM, respectively, followed by a seven digit number. For example, PLR 8210019 or TAM 9643001. The first two digits indicate the year the ruling was published, for example, 1982 and 1996, respectively . . .")