HOW TO OBTAIN IRS AUDIT INSURANCE: FUNDAMENTALS OF OBTAINING A PRIVATE LETTER RULLING ("PLR")

Whether you are a lay person, new professional, or a season professional, knowing that the Internal Revenue Service (“IRS”) issues binding tax guidance, which may act as audit insurance, will provide peace of mind with respect to a number of transactions.

The private letter ruling (“PLR”) provides this audit insurance.  The PLR is defined as a published administrative pronouncement that interprets the tax law as applied to a particular set of facts.  The PLR is binding on both the IRS and the taxpayer who receives the issued PLR.  Thus, the PLR protects the taxpayer against any future tax liability if the IRS subsequently challenges the tax treatment on audit or otherwise (“audit insurance”).

The HOW TO OBTAIN IRS AUDIT INSURANCE: FUNDAMENTALS OF OBTAINING A PRIVATE LETTER RULLING ("PLR") Handbook covers the following topics that are essential to understanding and submitting a PLR request to the IRS:

• Introduction to the Private Letter Ruling Process
• Understanding the Different Guidance Pronouncements
• Circumstances in Which the IRS Ordinarily Will Not Issue a PLR
• Understanding and Applying the PLR Request Ruling Areas
• Instructions and Guidelines for Requesting a PLR
• Submitting the PLR Request and Status Check
• IRS Processing of the PLR Request
• IRS Conferences to Discuss the PLR Request
• Revocation or Modification of a PLR
• Withdrawal of the PLR Request or IRS Declination to Issue a PLR
• The Insurance Effect of a PLR
• User Fee for a PLR Request
• Organizational Chart of the IRS
• Power of Attorney and Declaration of Representation
• Revenue Ruling 2008-1 (“Roadmap”)
• Sample PLR Issued by the IRS
• Bonus Report: : 13 Fundamental Strategies for Obtaining a Favorable Private Letter Ruling (“PLR”) Simplify and Manage the PLR Process

The Bonus Report is based upon more than 20 years of IRS experience as an attorney in the Office of Chief Counsel, Washington, D.C.  The HOW TO OBTAIN IRS AUDIT INSURANCE: FUNDAMENTALS OF OBTAINING A PRIVATE LETTER RULLING Handbook, which includes the Bonus Report, will demonstrate how to navigate the nuances of the PLR process in an area of tax practice where much of what is done is unwritten.  

Call Law Firm at 904-262-8003 or CONTACT US on line to discuss your PLR request, provide consultation, or purchase the158-page HOW TO OBTAIN IRS AUDIT INSURANCE: FUNDAMENTALS OF OBTAINING A PRIVATE LETTER RULLING.  Click, Online & E-Handbook Payments.

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