The Inner Income Service is pilot-testing a program for the subsequent yr and a half to expedite requests for rulings and willpower letters for company taxpayers.
The IRS issued a income process Friday establishing an 18-month pilot program to supply a possibility for fast-track processing of sure requests for letter rulings solely or primarily below the jurisdiction of the Affiliate Chief Counsel on the company aspect.
The IRS sometimes processes requests for letter rulings and willpower letters so as of the date after they’re acquired. A request for expedited dealing with must be made in writing to the IRS, “ideally in a separate letter included with the request for the letter ruling or supplied quickly after its submitting, and to elucidate intimately the necessity for expedited dealing with,” stated the IRS.
IRS headquarters in Washington, D.C.
Andrew Harrer/Bloomberg
There are solely sure circumstances during which the IRS will grant expedited dealing with of a letter ruling request. It’s normally granted “solely in uncommon and weird instances, out of equity to different taxpayers and since the Service seeks to course of all requests as expeditiously as potential and to present applicable deference to regular enterprise exigencies in all instances,” stated the IRS. The company could resolve to grant a request for expedited dealing with when there’s an element exterior a taxpayer’s management that creates an pressing enterprise must get a letter ruling or willpower letter earlier than a sure date to keep away from “critical enterprise penalties.”
The IRS and the Treasury are going to attempt to be extra versatile after coming below strain from corporations that want the letter rulings quicker, in order that they’re attempting out the brand new pilot program for 18 months to see the way it goes.
“The Division of the Treasury (Treasury Division) and the Service have acquired quite a few casual feedback from taxpayers and practitioners concerning the time required to course of letter ruling requests,” stated the brand new income process. “The Treasury Division and the Service have decided that quicker processing of sure requests for letter rulings solely or primarily below the jurisdiction of the Affiliate Chief Counsel (Company) would enhance service to taxpayers and improve sound administration of the company tax provisions of the Inner Income Code (Code).”
The IRS will attempt to course of the requests inside 12 weeks of when they’re acquired, until a shorter or longer time frame is requested and if the taxpayer suits the eligibility necessities. Company taxpayers might want to present a press release explaining the explanations for requesting fast-track processing, the size of the desired interval the requested (if apart from 12 weeks), any issues that might have an effect on the feasibility of fast-track processing, and another points related to the transaction, together with whether or not a ruling might be requested on every problem.