Private Letter Rulings Can Be a Costly, Secretive Affair


Alysse McLoughlin said that it is important to learn whether a taxing authority that issues private letter rulings is doing so only for a named taxpayer (which typically are binding) or if they also issue them anonymously (which may not be binding). Stephen Kranz added regarding letter rulings that “companies require clear guidance from the taxing authority, and the taxing authority should be bound by its word.”