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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.
IRS Written Determinations are documents the IRS is required to make "... open to public inspection..." pursuant to the provisions of I.R.C.IRS Written Determinations do not contain proprietary ("Official Use Only") information.
The IRS generally completes ruling requests within 60-90 days, although the process can take significantly longer if multiple branches of the IRS need to review the ruling or if there are other extenuating circumstances.
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.
Confirm there is a need. Get the most recent IRS guidance for making a ruling request. Is there an easier way to obtain a ruling? Confirm that the IRS has not declared your subject a no ruling topic. Seek direct guidance from the IRS. Don't forget to pay the user fee.
The Private Letter Ruling (PLR) fee increased from $10,000 to $28,300 in 2015 for an exempt organization (EO) with gross income of $1 million or more.