Private Letter Ruling Request
(to IRS)

Summary

This template is a private letter ruling request (PLR) that a taxpayer or the taxpayer's representative can customize to request guidance from the Internal Revenue Service (IRS or Service) on the tax treatment of the taxpayer's set of facts. PLRs are sometimes called "letter rulings," "advance rulings," "private rulings," or "rulings." This template includes practical guidance, drafting notes, and alternate and optional clauses. A PLR is a written request submitted by a specific taxpayer (an individual, business, or other entity) asking the IRS to address the tax consequences of a defined factual situation. See Federal Tax Practice and Procedure § 7.02. The procedures and user fees for obtaining a letter ruling are published annually in the first revenue procedure of each calendar year. For PLR requests made in calendar year 2025, the taxpayer's submission must follow Rev. Proc. 2025-1, which is effective for requests submitted on or after January 1, 2025. The IRS renews and republishes this revenue procedure each year. Rev. Proc. 2025-1 contains a nonexclusive list of circumstances in which the Service will and will not issue a letter ruling. See Rev. Proc. 2025-1, sections 5 and 6. The Service will not issue a letter ruling if the request involves an issue that is under examination, consideration, or litigation. See Rev. Proc. 2025-1, section 6. The Service ordinarily does not issue a letter ruling or determination letter if, at the time of the request, the identical issue is involved in the taxpayer's return for an earlier period and that issue: • Is being examined by a field office • Is being considered by Appeals • Is pending in litigation involving the taxpayer or a related party • Has been examined by a field office or considered by Appeals and the statutory period of limitations on assessment or refund has not expired –or– • Has been examined by a field office or considered by Appeals and a closing agreement covering the issue or liability has not been entered into by a field office or by Appeals. See Rev. Proc. 2025-1, sections 5 and 6; Federal Tax Practice and Procedure § 7.02. If the taxpayer files a return dealing with an issue for a particular year while a PLR on that issue is pending, an Associate office will issue the ruling unless it learns that examination of the issue, or of the same issue for an earlier year, has begun. See Rev. Proc. 2025-1, section 7.05. For income, gift, and estate tax matters, and for qualified retirement plan, IRA, and exempt organization cases, the Associate office may still issue the ruling if the examining office agrees in writing. The Service also may decline to issue a PLR or determination letter when the matter is primarily factual or otherwise unsuitable for ruling. See Rev. Proc. 2025-1, section 6. A taxpayer's authorized representative often signs the PLR request on behalf of the taxpayer. In those cases, the request should state: "A Power of Attorney is enclosed." See Rev. Proc. 2025-1, sections 7.01(14), 7.01(15), and 7.02(2). For more information on powers of attorney, see Power of Attorney and Power of Attorney Part 1 Video.