2015-02-05
Last month, the IRS released Rev. Proc. 2015-1. Among other things, the first revenue procedure of the year includes the new user fees for seeking relief under Treas. Reg. §301.9100 ("9100 relief"). A taxpayer might seek 9100 relief in order to make a late election, such as a late check-the-box election.
The private letter ruling user fee depends on the gross income of the taxpayer. Taxpayers with gross income of under $250,000 will have a 10% increase (to $2,200) in the user fee for requests received by the IRS after February 1, 2015. Taxpayers with gross income greater than $250,000 and less than 1 million will see a 30% increase (to $6,500), and taxpayers will gross income exceeding 1 million will have a 42% increase (to $9,800).
The graph below tracks user fees for private letter rulings to obtain 9100 relief from 2007 to 2015. The user fee for high-income taxpayers has come down since 2007. In contrast, the fee for low and medium income taxpayers has more than tripled since 2007.
