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Private Letter Ruling Requests

Maryland Tax Attorney Presenting Private Letter Ruling Requests

The Internal Revenue Service provides written rulings in response to taxpayer requests for guidance on prospective transactions.  Private Letter Rulings or PLRs are appropriate when a business, trust or individual taxpayer wants to receive guidance from the IRS on the federal tax consequences of a specific transaction before the transaction is consummated.  Private Letter Rulings are generally binding on the IRS, provided the taxpayer submits a full and accurate description of the contemplated transaction and carries out the transaction in the same manner set forth in the ruling request.   While a PLR will typically be made public once all taxpayer identifying information is removed, other taxpayers cannot rely on the PLR as precedent. 

Requests for Private Letter Rulings are typically handled by tax law attorneys with a deep understanding of IRS rules and procedures.  A skilled tax law team can help businesses and individual taxpayers determine when a private letter ruling is advisable in connection with a contemplated transaction and guide the taxpayer through each step of the process.  Your tax attorneys will carefully review your situation and should a PLR be deemed advantageous, they will work with you to gather all of the facts and information necessary to submit a ruling request petition to the IRS.

IRS Private Letters Ruling Address a Broad Range of Tax Matters

The IRS Private Letter Rulings program allows businesses and individual taxpayers to receive guidance from the IRS on a broad range of tax issues and situations.  When the IRS receives a PLR request, attorneys from the IRS Office of Chief Counsel with specialized knowledge in the specific subject matter area will interpret and apply the relevant tax laws to the facts set forth in the taxpayer’s Private Letter Ruling request. The Private Letter Ruling is meant to provide the business or taxpayer with certainty as to how the IRS will treat the particular transaction before the transaction takes place or the taxpayer files a federal tax return. 

While the PLR program is designed to address a diverse range of taxpayer issues and situations, there are a number of areas in which the IRS will refuse to issue a Private Letter Ruling.  For instance, the IRS ordinarily will not issue a Private Letter Ruling where the request involves a matter that is being examined by an IRS Field Office, is under consideration by IRS Appeals, or is pending in litigation in a case involving the taxpayer or a related taxpayer.  

Discuss Your Situation with Thorn Law Group

While Private Letter Rulings can provide very useful information to individuals and businesses, it is always best to consult with a tax law attorney to determine whether the IRS Private Letter Ruling program may be appropriate for your specific situation.  The attorneys at Thorn Law Group are skilled tax law professionals who counsel and advise clients throughout the Maryland region and around the nation on Private Letter Ruling requests.  Contact our Maryland offices today at 240-235-5096 or email ket@thornlawgroup.com to discuss how we can best assist you with your tax law issues and questions.


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