IRS Private Letter Rulings

A private letter ruling ("PLR") is a written determination by the Internal Revenue Service ("IRS") in response to a taxpayer's inquiry about its status for tax purposes or the tax effects of its proposed acts or transactions. A PLR is an IRS interpretation and application of the tax laws to the taxpayer's specific question based on the facts as presented to the IRS by the taxpayer. PLRs are not for minor issues or routine matters. Applying for a PLR can be a lengthy and complex process. Under the right circumstances, however, a PLR can be very valuable in carrying out tax-sensitive estate or business planning.

A taxpayer may rely on a PLR received from the IRS. However, a PLR is specific to the taxpayer that requested the ruling and may not be cited as authority to the IRS by other taxpayers. Nevertheless, tax attorneys and accountants often rely on PLRs as an indication of the Service's view on the matter at issue. PLRs are cited widely in scholarly articles and treatises.

When the IRS issues a PLR, a redacted version is made available to the public. You may be interested in the PLR relating to the tax effects of a proposed division of a GST exempt trust for which Stover & Spitz LLC prepared the application:

PLR 200629021