A letter sent by the IRS in response to a request for clarification or interpretation...
A ruling by the IRS in response to a request for interpretation of a tax law.
Represents the IRS's view on a specific transaction, a private letter ruling is an informational statement by the IRS interpreting how a statute or administrative rule applies to a particular set of facts or circumstances. Typically addresses a situation specific to a particular taxpayer and is generally not binding, as it is merely giving guidance on the IRS's current position. Taxpayers can refer to private letter rulings issued to other taxpayers to determine how their situation, if similar, may be interpreted by the IRS. However, a specific private letter ruling does not mean the IRS will rule the same way in a future similar situation -- For instance if significant time has passed since the original ruling and laws or circumstances may have changed during that time. However, a private letter ruling for a set of circumstances does offer a platform for argument if a future case is questioned. Some 1031 strategies are based on private letter rulings and any associated risk. Although a taxpayer is ultimately responsible for the decision to pursue a specific tax strategy, the qualified intermediary should inform them of associated risks.
An informal statement provided by the IRS at a taxpayer's request that reflects the IRS's position on a particular issue
A written response issued to a taxpayer by the National Office of the IRS that interprets and applies the tax laws to that taxpayer’s case. While private letter rulings may not be used as a precedent, they tend to predict IRS treatment of a similar case.
(USA) A letter sent by the Internal Revenue Servic... Add a comment
A formal document issued by the Internal Revenue Service announcing tax decisions or changes.
a ruling issued by the IRS addressing a particular tax situation of a taxpayer
a written statement issued by the IRS to a tax payer that interprets and applies the tax laws to the tax payer's specific set of facts
A private ruling issued by the IRS in response to a request from a taxpayer as to the tax consequences of a proposed or completed transaction. Private letter rulings are published informally by several publishers. They are not considered as precedent for use by taxpayers other than for the individual who requested the ruling, but they do give an indication of the IRS's current attitude as to a particular type of transaction.
A ruling provided by the IRS when requested by a taxpayer who wants to know how the tax laws apply to a particular factual situation. The ruling applies only to the taxpayer requesting it, and cannot be relied on by other taxpayers.
An Internal Revenue Service determination addressed to an individual taxpayer on a specific transaction that may be relied upon only by that particular taxpayer for that specific situation.
The response or interpretation issued by the Internal Revenue Service to a specific taxpayer or taxpayers about a specific question on tax law or a request for an interpretation of the tax code.
