General procedures for issuing letter rulings and determination letters are updated

The IRS has updated the general procedures for the issuance of written guidance in the form of letter rulings, closing agreements, determination letters and information letters, and orally on issues under the jurisdiction of the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), Associate Chief Counsel (Procedure and Administration), and Associate Chief Counsel (Tax Exempt and Government Entities).
In addition to minor revisions, notable changes include:

  • Section 11.04 is amended to clarify that a ruling can be revoked even if the subject of the ruling is a matter that the Service no longer rules on.
  • Sections 15.08 and 15.09 are amended to reflect that is now the exclusive means for making payments for user fees under this revenue procedure.
  • Section 15.09 was amended, and Appendix A, paragraph (B)(6) was added, to clarify the applicable user fee when a taxpayer’s gross income amount and eligibility for a reduced user fee under Appendix A, paragraph (A)(4), depends on receiving a favorable ruling.
  • Section 15.10 was amended to clarify the rules regarding refunds of fees paid under this revenue procedure.

The procedures are effective January 2, 2018.
Source: Rev. Proc. 2018-1.
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