letter ruling


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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.

letter ruling

letter ruling

A written statement from the IRS to a particular taxpayer, containing an interpretation of tax law as it applies to that taxpayer's situation. Letter rulings are issued in response to a request from a taxpayer and are not binding on the IRS as it relates to other cases.

References in periodicals archive ?
IRS Letter Ruling 201234034 ("Taxpayer A has not presented any evidence .
Although, as illustrated by the last example, the recipient taxpayer of a private letter ruling may rely on it, other taxpayers cannot.
In some circumstances, "it will be advantageous to both the (TRS) and the taxpayer to hold a conference before the taxpayer submits the letter ruling request," and the process and requirements for requesting such a conference are set out in Revenue Procedure 2010-1.
In Letter Ruling 201027015, the taxpayer provided a sample written acknowledgment with the charity's name and address, along with the date of the letter in the letterhead:
In general, the effects of a letter ruling issued under Rev.
71) Letter Ruling 200548021 (72) addressed the treatment of an S corporation that converted to an LLC, but checked the box to maintain its corporate status; it held that this would be treated as an F reorganization.
Letter ruling 200406054 (inclement weather barred taxpayer from making rollover until after 60-day period).
115 (stock interest to attract new president), and Letter Ruling No.
In Letter Ruling 200625009, a company and a co-owner had acquired a property and operated it as tenants in common.
This letter ruling, however, contains a hopeful sign that at least a portion of design costs may be eligible for a current deduction as software development.
Notwithstanding the lack of precedential value of private letter rulings, some revenue agents have asserted that the reasoning in Private Letter Ruling 9426004 supports the capitalization of relocation costs incurred as part of a company-wide restructuring.
2003-43, (3) which grants S corporations, qualified subchapter S subsidiaries (QSubs), ESBTs and QSSTs a 24-month extension to file Form 2553, Election by a Small Business Corporation, Form 8869, Qualified Subchapter S Subsidiary Election, or a trust election, without obtaining a letter ruling.