April 14, 2021

Volume XI, Number 104

Advertisement

April 13, 2021

Subscribe to Latest Legal News and Analysis

April 12, 2021

Subscribe to Latest Legal News and Analysis

You Can Now Submit Your Letter Rulings and Determinations to the IRS Electronically

Rev. Proc. 2020-29 temporarily allows taxpayers to submit certain requests for letter rulings and determinations to the Internal Revenue Service (IRS) electronically. Electronic submissions will be permitted until the revenue procedure is superseded or modified, but taxpayers may still make paper submissions.

Electronic submissions are permitted for requests for letter rulings, closing agreements, determination letters, and information letters from the Associate Chief Counsel Offices and for determination letters from the Large Business and International (LB&I) Division. However, procedures for submissions to the IRS Small Business/Self Employed Division, Wage and Investment Division, or Tax Exempt and Government Entities Division are unchanged.

The revenue procedure permits electronic submission by either fax or compressed and encrypted email, although the IRS prefers fax submissions for security reasons. Taxpayers submitting through email must include a signed Acknowledgment of Risks of Email, which include potential interception and access to sensitive or confidential information by unauthorized parties.

Taxpayers using the electronic submission procedures do not need to send multiple copies of documents. Any additional information or consent agreement required for a ruling or determination may also be submitted electronically. Taxpayers who previously submitted paper documents but have not yet received confirmation of receipt may resubmit the documents electronically for faster processing—however repeat submissions should be marked as such.

Practice Point: This new procedure is welcome news for taxpayers and the tax bar sitting at home frustrated about how to get their ruling requests to the IRS while stay-at-home orders are in place. Perhaps one good thing to come out of the current remote working environment is that the IRS’s electronic systems and procedures will enter into the modern age and be in more in line with today’s businesses. Hopefully Congress will allocate additional resources to the IRS to allow it to improve its technology.

Advertisement
© 2021 McDermott Will & EmeryNational Law Review, Volume X, Number 122
Advertisement
Advertisement

TRENDING LEGAL ANALYSIS

Advertisement
Advertisement

About this Author

Brian Moore Associate Washington, DC Tax  Federal Taxation  State & Local Tax  Tax Structuring
Associate

Brian Moore focuses his practice on US and international tax matters. While in law school, Brian served as an AmeriCorps JD Veterans Legal Assistance Intern for Legal Assistance of Western New York and he was an articles editor for the Yale Law and Policy Review. Prior to attending law school, he served as a research assistant for the White House Council of Economic Advisors where he assisted the chairman and members of the council in advising the president on tax policy and other public finance matters. Additionally, he was a research analyst for a global think tank and a research...

202-756-8246
Andrew R. Roberson tax attorney McDermott Will. Andy handles tax cases in Federal court, United States Tax Court
Partner

Andrew R. Roberson is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  Andy specializes in tax controversy and litigation matters, and has been involved in over 30 matters at all levels of the Federal court system, including the United States Tax Court, several US Courts of Appeal and the Supreme Court. 

Andy also represents clients, including participants in the CAP program, before the Internal Revenue Service Examination Division and Appeals Office, and has been successful in settling...

312-984-2732
Kevin Spencer, McDermott Will & Emery LLP , Tax Litigation Attorney
Partner

Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions.

 

In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of...

202-756-8203
Advertisement
Advertisement