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private letter ruling

   Also found in: Dictionary/thesaurus, Legal, Acronyms, Encyclopedia, Wikipedia 0.01 sec.
Private letter ruling
A ruling by the IRS in response to a request for interpretation of a tax law.

Ruling
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.

Private letter ruling. A private letter ruling explains a position the Internal Revenue Service (IRS) has taken on a specific issue or action that affects the amount of income tax a taxpayer owes.

While these rulings are not the law, and there's no guarantee that they won't be overturned by new IRS opinions, they can provide guidance on how to handle financial decisions that have potential tax consequences. There is a fee when you request such a ruling.


private letter ruling

An official IRS decision regarding how it will treat a transaction contemplated by the particular taxpayer who requested the private letter ruling.Private letter rulings are binding on the IRS for that one taxpayer, but other taxpayers are not entitled to rely on the position articulated in the ruling. Another taxpayer with an identical fact situation could find the IRS taking a completely different position.



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requests for relief after June 26, 2008), a taxpayer seeking relief had to request a private letter ruling under Regs.
Recent Private Letter Ruling Although the cases that address this issue are all fairly old, the IRS recently issued a private letter ruling, which addressed whether a trust transfer qualifies for split-gift treatment when the nondonor spouse is a trust beneficiary and the transfer exceeds the beneficiaries' withdrawal powers.
 
 
 
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