Request for a Private Letter Ruling 2025

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Private letter rulings are generally made public after all identifiable information about the taxpayer in question has been removed, and they can be accessed through the IRS FOIA Library.
Generally, an IRS PLR takes about 6-12 months to process for review and approval if approved an additional 6-12 months can be necessary for the delivery of the PLR to you or your representative if you are not in possession of it already.
Common abbreviations the you may encounter for private letter rulings are PLR and LTR, both indicate the same item. A determination letter is similar in purpose and nature to a private letter ruling, except that it is issued by the office of the local IRS district director not the national office of the IRS.
The IRS private letter ruling (PLR) user fee depends on the gross income of the taxpayer: For taxpayers with gross income under $250,000, the fee is $3,000. For taxpayers with gross income greater than $250,000 and less than $1 million, the fee is $8,500.
A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayers 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.

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A taxpayer or their representative may request a private letter ruling by forwarding the following information to OTR: Taxpayers name, business address and federal taxpayer identification number, Taxpayers facts and circumstances concerning the specific tax matter for which the taxpayer is requesting guidance,
How to Get a Private Letter Ruling? HONOR THE FIRST ANNUAL REVENUE PROCEDURE. REMEMBER TO DETERMINE IF THE IRS WILL RULE. CONSIDER THE PROPRIETY OF SUBMITTING A REQUEST. UNDERSTAND THE EFFECT OF A PLR. UNDERSTAND THE GENERAL PRECEDENTIAL VALUE OF A PLR. DO NOT FILE AN INCOMPLETE PLR REQUEST.

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