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Increases in Private Letter Ruling Fees for 2017


Earlier this month, the IRS released Rev. Proc. 2017-1.  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 entity classification election (also known as a “check-the-box election”) on Form 8832.

The new IRS fees are effective for requests received after February 1, 2017.  The amount of the user fee depends on the gross income of the taxpayer:

  1. Taxpayers with gross income of under $250,000 will have a 9% increase --- from $2,200 to $2,400
  2. Taxpayers with gross income greater than $250,000 and less than $1 million will have a 17% increase --- from $6,500 to $7,600
  3. Taxpayers with gross income of $1 million or more will have a 2% increase --- from $9,800 to $10,000

The graph below tracks these user fees from 2007 to 2017.  The 2017 user fee for high-income taxpayers is the same as it was in 2007.  In contrast, the 2017 user fee for low and medium income taxpayers has more than tripled since 2007.


Tags: Authority - Revenue Procedures, Form 8832