2023-12-30
Yesterday the IRS released Rev. Proc. 2024-1. 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 (“PLR”) user fee depends on the gross income of the taxpayer:
This fee has remained the same now for four years in a row. The graph below shows these user fees from 2014 to 2024.