IRS Letter

How Private Letter Rulings are Useful to Tax Pros


The private letter ruling (PLR) is a fact-specific, written determination by the IRS responding to a written request by a particular taxpayer. Individuals, corporations, exempt organizations, all kinds of taxpayers get rulings on all kinds of tax issues. Here's what tax pros need to know about them.

Oct 6th 2021
Share this content

While not precedential, private letter rulings (PLRs) are often an important element in one’s tax research for a particular client. 

There are many issues that the IRS will not address in a private letter ruling. These are usually tax technical or factual in the nature. The taxpayer asking for the ruling needs to be identified to the IRS. 


As guidance to other taxpayers, PLRs do not have the importance of published rulings. 

“A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's specific set of facts. A PLR is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer's return is filed….” (.Understanding IRS Guidance – A Brief Primer,”,

The IRS goes on to explain the analysis is made public but in a manner that maintains confidentiality, and that it isn’t to be “relied on as precedent by other taxpayers or IRS personnel.”(Ibid)

Register for free to continue reading

It’s 100% free and provides unlimited access to the latest accounting news, advice and insight every day. As well as access to this exclusive article, you can:

Content lock down, tick icon

View all AccountingWEB content

Content lock down, tick icon

Comment on articles

Access content now

Already have an account?

Replies (0)

Please login or register to join the discussion.

There are currently no replies, be the first to post a reply.