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A private letter ruling is an IRS interpretation of rules and their application in response to a particular taxpayer's complex set of circumstances.
Private letter rulings, commonly known as "guidances," are the bane of tax attorneys everywhere. They are very specific, vast in number and essential to understanding how tax law works. In brief ...
The IRS ordinarily will not issue “comfort” letter rulings on matters that are already squarely addressed by statute, regulation, court decision, revenue ruling, revenue procedure or notice. Get the ...
To request a private letter ruling under the pilot program, a taxpayer must follow the general procedures in Revenue Procedure 2017-1. 6 Further, Section 3 of Revenue Procedure 2017-52 requires a ...
Private letter rulings, commonly known as "guidances," are the bane of tax attorneys everywhere. They are very specific, vast in number and essential to understanding how tax law works. In brief ...
However, the IRS has provided more detailed information in private-letter rulings on the private business use test, he said. For reprint and licensing requests for this article, click here.
The private-letter ruling only applies to the unnamed company that requested it. Other employers interested in pursuing a similar choice program would need to seek their own ruling.
The employer’s request specifically asks the IRS to weigh in on the proper treatment of the assets under Section 4980 of the Internal Revenue Code. As recounted in the private letter ruling, the ...
Private letter rulings can provide insight into future benefits trends. For example, a provision in the SECURE 2.0 Act allowing employers to match student loan payments by employees with ...
When a transaction requires greater certainty or when relief is sought for a difficult tax situation, applying to the IRS for a private letter ruling (PLR) can provide interpretation and application ...
How a Private Letter Ruling (PLR) Works. A private letter ruling is specific and applicable only to an individual taxpayer and their tax situation at the time of the request.