I Don’t Have the Answer. Asking the IRS for a Private Letter Ruling

Getting answers from the IRS can involve the Private Letter Ruling (PLR) process of submitting a detailed request to the IRS. It must include a complete statement of all facts relating to the transaction, a statement of the business reasons for the transaction, and a detailed description of the transaction in question. Treas. Reg. § 601.201(a)(2). PLRs are sometimes referred to as "letter rulings," "advance rulings," "private rulings," or sometimes just "rulings." 

Read now »

Related Content

• Practice Before the IRS Essentials Checklist
  Reference this checklist for signposts and steps to follow in practice before the Internal Revenue Service (IRS), including awareness issues, agreements during examinations, settlement procedures, closing agreements, and offers in compromise.  

• Private Letter Ruling (to IRS)
  Use and customize this private letter ruling template to request guidance from the IRS on the tax treatment of the taxpayer's set of facts. For PLR requests made in calendar year 2024, the taxpayer's written request should follow the procedures outlined in Revenue Procedure 2024-1, which is effective for PLRs requested from January 1, 2024. The IRS annually renews the PLR request procedure in a published revenue procedure.

Practical Guidance Updates 
Featuring the latest updates from your Practical Guidance account.    

•  Tax Key Legal Developments Tracker (Federal)—keep up to date with key legal developments!
  • Business Entities. IRS advises taxpayers of its position challenging certain partnership related-party transactions under the codified economic substance doctrine in R.C. § 7701(o). Specifically, the IRS addresses the question: "Does the economic substance doctrine apply to disallow tax benefits associated with a series of transactions involving a related-party partnership, through which the parties first generate a disparity between inside basis and outside basis and then trigger a basis adjustment to property under I.R.C. § 732(b), § 734(b), or § 743(b), which generates increased cost recovery deductions with respect to the property or reduced gain (or increased loss) upon a sale of the property?" Rev. Rul. 2024-14.
  • Business Entities. IRS and Treasury Department announce they intend to publish two sets of forthcoming proposed regulations that would address certain basis-shifting transactions involving partnerships and related parties. Such transactions, referred to as “covered transactions”, (1) involve partners in a partnership and their related parties, and (2) result in increases to the basis of property. Notice 2024-54.
• Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts. 
• For Practical Guidance content on important recent trends, please review easy-to-use Resource Kits on these emerging topics:

• • Generative Artificial Intelligence (AI) Resource Kit
  • Environmental, Social, and Governance (ESG) Resource Kit
  • Public Interest, Pro Bono, and Non-Profit Resource Kit
• Review this guidance, AI and Legal Ethics: What Lawyers Need to Know, in the Summer Edition of the Practical Guidance Journal. Explore insights from a judge into the use of GenAI in civil litigation, including discovery issues, use cases, and key takeaways. Also advance your career with professional and business development guidance.
• Learn about the 2000+ leading attorney authors contributing to our 26 practice areas in the Practical Guidance Author Center. Interested in becoming a Practical Guidance author? Click here for details. Practical Guidance is committed to amplifying diverse voices of attorneys across all differences, including gender and race.  
• Legal Developments provide the latest updates and analyses of emerging topics impacting your practice area. Visit the Legal Developments page to see the latest topics, which also include breaking legal news and related Practical Guidance content. 
• New and Recently Updated Practical Guidance Content
  • Conservation Easements, Donor Advised Funds, and Sponsoring Organizations: Governing Principles
  • Section 367(b) Proposed Regulations on Triangular Reorganizations and Inbound Nonrecognition Transactions
  • Proposed Regulations on Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest

PRACTICAL GUIDANCE CUSTOMER EMAIL EDITION ON THE WEB

Experience results today with practical guidance, legal research, and data-driven insights—all in one place.

Experience Lexis+