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Related to Private Rulings: Private Letter Rulings


An official opinion by the IRS on how it interprets U.S. tax law. The IRS may make a ruling, for example, after seeing taxpayers apply a deduction or credit to an unusual, but still relevant situation. The IRS determines whether or not it will accept the situation, and, afterward, applies the ruling to all comparable situations. It is also called a revenue ruling, a letter ruling, or a private letter ruling.


References in periodicals archive ?
The attack has been in the form of private rulings and litigation.
field service advice, private rulings and technical advice memoranda, notices, revenue rulings, and regulations)?
TEI believes that the term should not include methods that are contrary to methods set forth in IRS Notices, Announcements, or private rulings.
Private rulings of this sort are considered confidential information not subject to release in other than redacted form by the state.
On June 11, 1997, Tax Executives Institute submitted the following comments to the Internal Revenue Service on IRS Notice 97-7, which sets forth a draft revenue procedure on obtaining private rulings from the agency on the proper tax treatment of environmental remediation expenditures.
Moreover, by issuing public guidance earlier rather than later, scarce government and taxpayer resources that would otherwise be devoted to the resolution of these issues through examinations, appeals, private rulings, and litigation would be freed for other uses.
Taxpayers can invoke "the reasoning" of private rulings, too, but their success in doing so may depend on their willingness to pursue matters to litigation.
28) These private rulings apply the revenue ruling and the regulations just as they are applied in wholly domestic situations, without any suggestion that the cross-border nature of the transaction has any effect on the analysis.

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