IRS issues annual guidance on obtaining private letter rulings

The IRS released Rev. Proc. 2018-1, which explains how the IRS provides advice to taxpayers on issues under the jurisdiction of the Office of Chief Counsel. Advice may be sought by taxpayers in the form of a private letter ruling (PLR), information letter, and closing agreement, among other ways.

Rev. Proc. 2018-1 describes the procedures by which a taxpayer may request advice from the IRS. For example, taxpayers routinely request PLRs from the appropriate Office of Associate Chief Counsel. Such requests must follow certain guidelines, and typically require a user fee.

User fees remained largely unchanged from 2017. Requests for a PLR, closing agreement, letter ruling request pursuant to Treasury Reg. Sec. 301.9100-1 (so-called “9100 relief”) remained unchanged from last year. Notably, the user fee for a pre-filing agreement was reduced substantially for 2018 — from $218,600 to $174,000.

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