IRS issues annual guidance on letter rulings

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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.


David Auclair
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