Legal Definitions - private letter ruling

A private letter ruling is a written statement issued by the Internal Revenue Service (IRS) to a taxpayer who has inquired about the tax implications of a specific transaction. This ruling explains how the transaction will be taxed and helps the taxpayer make informed decisions about their finances.

For example, if a taxpayer is considering selling a piece of property and wants to know how the sale will be taxed, they can request a private letter ruling from the IRS. The ruling will provide guidance on how the sale will be taxed and any potential tax consequences.

Another example is if a taxpayer is unsure about how to report income from a foreign source on their tax return. They can request a private letter ruling from the IRS to clarify the reporting requirements and avoid any penalties for incorrect reporting.

Private letter rulings are only applicable to the taxpayer who requested them and cannot be relied upon by other taxpayers or used as precedent in future cases. They are confidential and not made public by the IRS.