What is the difference between an IRS determination letter and an IRS private letter ruling?
January 24, 2009 by Tax Blog
Filed under Questions & Answers
Joel P asked:
It appears the fee schedule is different the determination letter is less expensive, but which would a taxpayer use for an individual IRS question regarding taxes?
It appears the fee schedule is different the determination letter is less expensive, but which would a taxpayer use for an individual IRS question regarding taxes?
v b on Sun, 25th Jan 2009 6:24 am
Private Letter Ruling.
Determination letters are for things like tax-exempt groups.
recycle b on Sun, 25th Jan 2009 8:31 am
Private Letter Ruling is the IRS advance position paper give to you based on the facts you provide to them regarding deductions, income, mergers, acquistions etc. It will provide the tax law and conclusion that is relevant to your situation only, once again based on the facts and circumstances you have provided. At a latter time the IRS may audit the tax return to determine if the facts are the same as provided in the PLR.
A determination is usually used for pension plan determinations to see if there are not any discrimination.