Private Letter Ruling Requests
When You Need to Request a Private Letter Ruling Regarding Tax Consequences of Planned Transactions
If your business is about to embark on complex transactions, such as selling offshore manufacturing installations or preparing for a merger and acquisition, your company will require a detailed prediction as to the tax consequences. While your tax advisor will have an opinion as to the tax consequences, you may also wish to make a private letter ruling request to the IRS.
If your business is preparing to petition the IRS for a private letter ruling, the assistance and guidance of an experienced tax litigation attorney is recommended. Lawyer Lawrence Brown of Brown, PC has decades of experience handling tax controversies.
Preparing your request for a private letter ruling will require detailed descriptions of an array of specific facts. Attorney Brown, a former Trial Attorney with the Department of Justice Tax Division, is well acquainted with potential pitfalls and problem areas.
Sometimes clients seek a private letter ruling in anticipation of an expected IRS tax audit — a prudent measure in many cases when there are issues such as valuation, capital gains or employment tax disputes to take into account. For many businesses, understanding the likely consequences of a complex transaction before entering into the transaction is of vital importance.
Call Brown, PC to Schedule an Initial Consultation
Contact Brown, PC in Dallas-Fort Worth, Texas, regarding complex tax controversies and questions from wherever you are in North America or the world. Call 888-870-0025 to discuss problems or questions with an experienced tax litigation attorney.