Private Letter Rulings

Private Letter Rulings

Definition of Private Letter Rulings

Private Letter Ruling means: a reply from the U.S. Internal Revenue Service regarding the tax treatment of a proposed transaction. At one time, private letter rulings were unpublished, but they have been made public information and are later published by several private companies. Nonetheless, only the party to whom the private ruling was issued may rely on it.

Overview

A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer’s specific set of facts. A PLR is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer’s return is filed. A PLR is issued in response to a written request submitted by a taxpayer and is binding on the IRS if the taxpayer fully and accurately described the proposed transaction in the request and carries out the transaction as described. A PLR may not be relied on as precedent by other taxpayers or IRS personnel. PLRs are generally made public after all information has been removed that could identify the taxpayer to whom it was issued.

A Private letter ruling is “[a] written statement issued to the taxpayer by the Internal Revenue Service in which interpretations of the tax law are made and applied to a specific set of facts. [The] [f]unction of the letter ruling, usually sought by the taxpayer in advance of a contemplated transaction, is to advise the taxpayer regarding the tax treatment he can expect from the I.R.S. in the circumstances specified by the ruling.” Black’s Law Dictionary, p. 1196 (6th ed. 1990)(West Publishing Company)(citing U.S. v. Wahlin, D.C.Wis., 384 F.Supp. 43, 47.) “. . . [U]nless the Secretary establishes otherwise by regulations, a “written determination” may not be used or cited as precedent by another taxpayer. Sec. 6110(j)(3); sec. 301.6110-7(b), Proced. & Admin. Regs. Written determinations include both private rulings and technical advice memoranda . . . . Sec. 301.6110-2(a), Proced. & Admin. Regs.” Lucky Stores, Inc. v. Commissioner, T.C. Memo. 1997-70 (1997)

Locating and Citing Private Letter Rulings

Locating Private Letter Rulings

Private Letter Rulings are published in:

Westlaw: FTX-WD and FTX-PLR These databases contain Private Letter Rulings from 1954 to the present.
Lexis: FEDTAX;PLR This database contains Private Letter Rulings from 1954 to the present.

IRS Website, in IRS Written Determinations: This website, within the IRS’s Electronic Reading Room, contains the text of some Private Letter Rulings from 1997 to the present.

Print and Online Sources:

  • CCH’s Standard Federal Tax Reporter contains annotations to Private Letter Rulings in its compilation volumes following each IRC section. CCH’s online product, CCH Tax Research NetWork, contains the text of Private Letter Rulings in the Federal Tab in the “Rulings & Other Docs.” section under Primary Sources.
  • RIA’s United States Tax Reporter contains annotations to Private Letter Rulings in its compilation volumes following each IRC section. RIA’s online product, RIA Checkpoint, contains the text of Private Letter Rulings which can be accessed via the “Rulings/IRB” section on the left side of the screen under Find By Citation or by searching in the “IRS Rulings and Releases” database under the Primary Source Materials heading.

Print Sources:

IRS Letter Rulings Reporter KF 6289 .A353
CCH’s IRS Positions Reporter KF 6300 .A833

Citing Private Letter Rulings

See Bluebook Rule 14.5.2(b).

Example:

  • Priv. Ltr. Rul. 86-1-012 (Sept. 30, 1985)

Private Letter Rulings available elsewhere

When Private Letter Rulings are not yet available on the American Tax Encyclopedia, can be found on the following external site(s):

Private Letter Rulings Examples

Some Private letter rulings are the following:

  • Private Letter Ruling Number: 201538027 Internal Revenue Service February 19, 2015 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE TEGE EO Examinations Mail Stop 4920 DAL 1100 Commerce St.
  • Chief Counsel Advice Number: 201545016 Internal Revenue Service July 17, 2015 Office of Chief Counsel Internal Revenue Service memorandum Number: 201545016 Release Date: 11/6/2015 CC:PA:01:HMarch POSTF-112882-15
  • Private Letter Ruling Number: 201609006 Internal Revenue Service April 9, 2015 DEPARTMENT OF THE TREASURY Internal Revenue Service TE/GE EO Examinations 1100 Commerce Street
  • Private Letter Ruling Number: 201613016 Internal Revenue Service December 28, 2015 Department of the Treasury Internal Revenue Service Appeals Office Release Number: 201613016
  • Private Letter Ruling Number: 201543019 Internal Revenue Service July 29, 2015 Department of the Treasury Internal Revenue Service Appeals Office Release Number: 201543019
  • Private Letter Ruling Number: 201609008 Internal Revenue Service December 3, 2015 Department of the Treasury Internal Revenue Service Appeals Office Release Number: 201609008
  • Private Letter Ruling Number: 201525013 Internal Revenue Service March 6, 2015 Department of the Treasury Internal Revenue Service Appeals Office Release Number: 201525013
  • Private Letter Ruling Number: 201512001 Internal Revenue Service September 30, 2014 Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 201512001
  • Private Letter Ruling Number: 201603042 Internal Revenue Service September 28, 2015 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE TE/GE: EO Examinations 1100 Commerce Street, MC 4920 DAL
  • Private Letter Ruling Number: 201531022 Internal Revenue Service February 27, 2015 Department of the Treasury Internal Revenue Service Appeals Office Release Number: 201531022
  • Private Letter Ruling Number: 201547007 Internal Revenue Service September 5, 2014 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE TE/GE: EO Examination 1100 Commerce Street
  • Private Letter Ruling Number: 201603039 Internal Revenue Service September 23, 2015 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE TEGE:EO Examinations 1100 Commerce Street, MC 4920
  • Private Letter Ruling Number: 201514016 Internal Revenue Service January 6, 2015 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION
  • Private Letter Ruling Number: 201513005 Internal Revenue Service December 31, 2014 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION
  • Private Letter Ruling Number: 201548024 Internal Revenue Service August 28, 2015 Department of the Treasury Internal Revenue Service TEGE Appeals Programs 300 N. Los Angeles Street
  • Chief Counsel Advice Number: 201521013 Internal Revenue Service December 18, 2014 Office of Chief Counsel Internal Revenue Service memorandum Number: 201521013 Release Date: 5/22/2015 CC:TEGE:EB:EC POSTU-107896-14
  • Private Letter Ruling Number: 201518020 Internal Revenue Service February 6, 2015 Department of the Treasury Internal Revenue Service Appeals Office Royal Palm One, Suite 350
  • Chief Counsel Advice Number: 201515020 Internal Revenue Service December 4, 2014 Office of Chief Counsel Internal Revenue Service memorandum Number: 201515020 Release Date: 4/10/2015 CC:FIP:Br1:RAMartin POSTS-117317-14 UILC: 9300.00-00 date: December 04, 2014
  • Chief Counsel Advice Number: 201534013 Internal Revenue Service Date: not given ID: CCA_2015073118010399 UILC: 9413.04-00 Number: 201534013 Release Date: 8/21/2015 From: Sent: Friday, July 31, 2015 6:01:04 PM To: Cc: Bcc: Subject: Application of section 905(c)
  • Private Letter Ruling Number: 201610025 Internal Revenue Service December 11, 2015 Department of the Treasury Internal Revenue Service Appeals Office San Jose Appeals, MS-7100

See also other Tax Terms and Definitions in U.S.A.

Advance ruling


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