The IRS on Jan. 4 released its annual procedures for obtaining
private letter rulings (PLRs) and determination letters, as well as
its list of types of issues for which the Office of Chief Counsel
would not give a ruling.
Rev. Proc. 2016-1, which provides guidance on
how the IRS issues PLRs and determination letters, was modified
slightly from its predecessor procedure, Rev. Proc. 2015-1. The
updated revenue procedure specifically refers to procedures for
taxpayers wishing to revoke an election, indicating that the
taxpayer should file for relief under Treas. Reg. Sec. 301.9100
(called 9100 relief).
Rev. Proc. 2016-1 also provides users with fee information for
obtaining such rulings. For requests received by the IRS after Feb.
5, 2015, the fee for a PLR is $28,300, which is the same as last
year. The user fee for obtaining 9100 relief is $9,800, which
is also the same.
Rev. Proc. 2016-3 lists those areas of the code
under the jurisdiction of certain Associate Chief Counsel offices
within the IRS Office of Chief Counsel, in which the IRS will not
issue letter rulings or determination letters. The IRS deleted
three issues from the list (regarding Sections 45, 704(e) and 162
and 1502), and added 17 issues, some of which deal with Section 355
spin-off transactions and Rev. Proc. 2015-43.
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