Private Letter Rulings (colloquially called “PLRs”) are written
statements from attorneys at the IRS Chief Counsel’s Office. In a nutshell PLRs
are requested by taxpayers prior to undertaking a specific transaction, when
the law is unclear (indeed).
PLRs are granted only with respect to proposed transactions or
completed transactions for which a return has not yet been filed.
Mucho más importante, PLRs can only be relied upon by the
party that requested the ruling.
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