The IRS on Aug. 24 updated the Internal Revenue Manual (IRM) to reflect changes to the way the Appeals Division functions, In Notice 2016-59, the IRS provided changes to Rev. Proc. 2016-1, which governs the procedures and cost for obtaining a private letter ruling (PLR) from the IRS Office of Chief Counsel.
Under Rev. Proc. 2016-1, the current user fee for a PLR is $28,300. Taxpayers requesting a PLR may qualify for a reduced user fee for a substantially identical PLR if the subsequent PLR is requested for multiple entities with a common member or sponsor, or multiple members of a common entity. The reduced user fee for each substantially identical PLR is $2,700.
The notice expands the availability of the reduced user fee to include substantially identical PLRs requested by parties that are engaged together in the same transaction affecting all requesting taxpayers. The change is effective immediately and will be reflected in Rev. Proc. 2017-1, which is typically published in early January of each year. Finally, the notice also decreases the user fee for a request for a Foreign Insurance Excise Tax Waiver Agreement from $8,000 to $7,200, for requests received after Feb. 4, 2016. The IRS said the reduced fee was omitted inadvertently from Rev. Proc. 2016-1.
National Managing Principal, Washington National Tax Office
+1 202 521 1515
Manager, Washington National Tax Office
+1 202 521 1511
Tax professional standards statement
This content 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 topics presented herein, we encourage you to contact us or an independent tax professional to discuss their 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 content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content 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.