The Internal Revenue Service has announced a pilot program, effective immediately, to fast-track private letter decisions (PLRs) in the Revenue Process 2022-10. Under the new pilot program, eligible corporate taxpayer requests that are wholly or primarily under the jurisdiction of the IRS Office of Associate Chiefs Council (Corporate) may be processed within 12 weeks of receipt.
The program comes after the IRS took heat from physicians regarding the lag in response times. If successful, the 18-month pilot program, which runs until July 14, 2023, or until a supersession revenue process is issued, will become permanent.
Requirements
To request fast-track processing, a taxpayer must first request a pre-submission convention with the IRS. Prior to the convention, the taxpayer must make a statement explaining the reasons for requesting fast-track processing, the desired processing time (if less or more than 12 weeks), any facts that may result in fast-track processing and whether any issue is under the jurisdiction of any other associate offices.
Factors used to determine the feasibility of a request include: the completeness of the taxpayer’s request and supporting documentation, the adequacy of the draft PLR and the need for collaboration with other supporting offices. Requests which seek PLR also in the jurisdiction of other associate offices will be subject to those other offices agreeing to fast-track processing.
Those taxpayers with PLR who are already pending in January. 14 (from the date on which the pilot program came into effect) may seek fast-track processing under Rev. By agreeing to follow the Procurement 2022-10 Pilot Program procedures, a pre-submission convention is not required.
Pilot program replaces early operations
Switches accelerated handling request processes to pilot programmable PLRs for fast-track processing. The IRS notes that “fast-track processing is not available for requests for extension of time to make election or other applications for relief under section 301.9100 of the Procedure and Administration Regulations (26 CFR Part 301) (Section 9100 Relief)” ” However, in those requests Rev. Purchase 2022-1.
