Private Letter Ruling Requests

A Private Letter Ruling (“PLR”) is a written statement issued by the IRS to a taxpayer who is seeking guidance on a specific matter. Traditionally, business, trust and individual taxpayers request private letter rulings in advance of completing a contemplated transaction.

In a Private Letter Ruling, the corporate or individual taxpayer submits a statement detailing the proposed transaction. Attorneys from the IRS Office of Chief Counsel who specialize in the subject matter area of the request interpret and apply the tax laws to the requesting taxpayer’s specific set of facts. The letter ruling offers the business or individual taxpayer certainty as to how the IRS views the anticipated transaction and the tax treatment the taxpayer can expect from the IRS based on the specific facts presented in the PLR request and ruling. For this reason, private letter rulings can be very useful to individuals and businesses contemplating transactions or activities that, if improperly structured, could have costly tax consequences.

At Thorn Law Group, we are experienced at presenting private letter ruling requests to the IRS. If you wish to seek technical guidance from the IRS prior to entering a transaction, contact Kevin E. Thorn at 202 349-4033 today to discuss whether a requesting a PLR is right for you.




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