Practice Subgroup

Federal and state private letter ruling requests

Prior to filing applicable tax returns, when existing law may not provide a clear answer with respect to particular tax aspects of a transaction or act, our attorneys have obtained Federal and State Private Letter Rulings. While not appropriate in all circumstances, when obtaining a level of certainty is a top priority, the appropriate business decision may be to file a request for a Private Letter Ruling from the IRS or appropriate state authority. Although Private Letter Rulings are not issued on alternative plans of proposed transactions or on hypothetical situations, a ruling may be requested prior to consummating a proposed transaction or act. Critical to filing a timely request for a Private Letter Ruling is to do so prior to the applicable tax return being filed. Clients seeking our tax advice in a timely matter is also critical. Our attorneys can then counsel clients on whether filing a Private Letter Ruling Request is advisable or, based upon our research and experience, even necessary.