A Private Letter Ruling (PLR) is a coveted letter issued by the IRS to a specific taxpayer concerning the tax law and application to one or more specific set of facts represented by the taxpayer, that are unclear. Although the PLR may only be relied upon by the taxpayer to whom it is issued, PLRs are often cited by practitioners as instructive on how a certain matter should be treated for tax purposes.
There is no right to a PLR; the IRS determines which issues it will review and publishes a list of those it will not consider. The process can be time-consuming, and expensive, for the taxpayer.
Although the IRS has a process for requesting an expedited PLR, it now has a Fast-Track Program for qualifying taxpayers, as described in Revenue Procedure 2023-26. There are several criteria that must be met, including a request for a pre-submission conference, and must explain why the taxpayer requires an answer in less than 12 weeks (although there is no requirement that the taxpayer demonstrate a business need for requesting fast-track processing).
To read the complete Revenue Procedure, click here.