March 01, 1990
New Schedule for User Fees Announced
WASHINGTON - The Internal Revenue Service today announced a
new schedule of user fees for requests for private letter rulings
and determination letters. Although some of the fees have been
lowered, many of them are higher than the current ones.
The new fees are generally effective for ruling requests made
after March 31, 1990. The fee increase for opinion and
determination letter requests in the Employee Plans and Exempt
Organizations areas have generally been delayed until Oct. 1, 1990.
The IRS began charging fees for rulings in 1988, as required by
the Revenue Act of 1987. Under that law, user fees must take into
account the average time for complying with ruling requests and the
difficulty of the subject matter of the requests. The law also
allows the IRS to establish exceptions and reduced fees in
The fees announced today result from reviews the IRS conducted
in 1989 of the direct and indirect costs and the time involved in
preparing rulings and determination letters. The reviews showed
that most of the existing user fees, which were published in Revenue
Procedure 89-4, did not accurately reflect the complexity of the tax
issues and the time required to answer the requests and that they
should be raised. The IRS noted, however, that fees for certain
categories of requests have not changed and some have been reduced.
- Under Revenue Procedure 90-17, which was released today, some
of the following fees that have increased are:
- $200 for Chief Counsel ruling requests on accounting
- $500 for Chief Counsel ruling requests for changes in
- $2,500 for other Chief Counsel ruling requests;
- $1,250 for Employee Plans and Exempt Organizations
National Office ruling requests, and
- $3,000 for employee plans submitted by one plan sponsor which
will be used by 50 or more employers in the Employee Plans
Master and Prototype program.
- Fees for the following categories of requests are unchanged:
- $50 for requests from retirees for calculating the tax
treatment of retirement annuity payments, and
- $150 for determination letter requests from small exempt
- Fees for the following categories of requests were reduced:
- $375 for determination letter requests for certain
employee plan terminations, reduced from $450, and
- $500 for certain opinion letter requests from sponsors of
Individual Retirement Arrangements in the Employee Plans
Master and Prototype program, reduced from $1,000.
The IRS said that lower fees apply for some ruling requests on
behalf of taxpayers and exempt organizations with income or assets
below certain dollar amounts. For example, a lower fee for a ruling
request for an individual whose total income reported on a return is
less than $150,000 will be $500 rather than $2,500.
As in the past, no fee will be charged for requests for general
information letters on tax issues. A general information letter
issued to a taxpayer sets forth principles of tax law without
applying the tax law to the taxpayer's specific factual situation.
The IRS also reminded retirees that they can avoid the fee for a
request for calculating the tax treatment of retirement annuity
payments by using a special simplified method explained in
Publication 575, "Pension and Annuity Income," and Publication 721,
"Comprehensive Tax Guide to U. S. Civil Service Retirement
Benefits." Both publications can be ordered by calling the IRS
toll-free at 1-800-424-3676.
Revenue Procedure 90-17, containing the new user fees, will be
published in Internal Revenue Bulletin 1990-12 on March 19, 1990.
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