A private letter ruling is an IRS interpretation of rules and their application in response to a particular taxpayer's complex set of circumstances.

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 ...

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 ...

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 ...

In Revenue Procedure 2021-1, the service revised the procedures for obtaining private letter rulings from the IRS Office of Chief Counsel.The OCC said it conducted a biennial review of the user fees ...

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.

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 ...

On February 7, 2025, the IRS released Private Letter Ruling No. 202506001 in which it concluded that a management contract providing an incentive fee equal to a percentage of gross revenues of a ...

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.