2024-12-29
On Friday the IRS released Rev. Proc. 2025-1. The first revenue procedure of the year includes, among other things, 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 entity classification/check-the-box election (see Form 8832).
The IRS private letter ruling user fee depends on the gross income of the taxpayer. For all three categories, the user fee increased by 15%.
The new user fees are effective as of February 2, 2025. The graph below shows the user fees from 2014 to 2025.