Close
Close

IRS issues annual guidance on letter rulings

RFP
Tax Hot TopicsTax Hot Topics
The IRS released on Jan. 2 its annual guidance related to obtaining private letter rulings, technical advice and the list of issues on which the IRS would not issue a ruling.

Rev. Proc. 2015-1 is the procedure for applying for a private letter ruling, including regulatory relief under Treas. Reg. Sec. 301.9100-1 — so-called “9100 relief” for missed elections. The user fee for 9100 relief increases from $6,900 to $9,800 for requests received by the IRS after Jan. 31, 2015. The fee for letter ruling requests in general increase from $19,000 to $28,300.

In addition, the fee for nonautomatic method changes on Form 3115 increases from $7,000 to $8,600 for the first applicant, and from $150 to $180 for each additional applicant on the same form. There is no user fee for automatic method changes listed under Rev. Proc. 2011-14 or other published guidance.

Rev. Proc. 2015-2 is the procedure for obtaining the IRS’s technical advice on a technical or procedural matter. Rev. Proc. 2015-3 is the list of issues on which the IRS will not issue a letter ruling or determination letter.

Contact

David Auclair
+1 202 521 1515
david.auclair@us.gt.com

Tax professional standards statement
This document supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the subject of this document, we encourage you to contact us or an independent tax adviser to discuss the potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this document may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this document is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.

The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.