On January 3, 2023, the Internal Revenue Service published Internal Revenue Bulletin: 2023-1 (https://lnkd.in/eWdbmer5), which contains the Revenue Procedures (Rev. Proc.) for 2023 on letter rulings, technical advice, and determination letters.
Revenue Procedure 2023-1, in particular, contains revised procedures for letter rulings and information letters issued by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), and Associate Chief Counsel (Procedure and Administration).
A “letter ruling” is a written determination issued to a taxpayer by one of the above Associate offices in response to a taxpayer’s written inquiry, filed prior to the filing of returns or reports that are required by the tax laws, about its status for tax purposes or the tax effects of its acts or transactions. A letter ruling interprets the tax laws and applies them to the taxpayer’s specific set of facts and is issued, when appropriate, in the interest of sound tax administration. Rev. Proc. 2023-1 explains the forms of advice and the manner in which advice is requested by taxpayers and provided by the Service.