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2024 PLR Fees For 9100 Relief Remain the Same


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:

  • For taxpayers with gross income under $250,000, the fee is $3,000.
  • For taxpayers with gross income greater than $250,000 and less than $1 million, the fee is $8,500.
  • For taxpayers with gross income exceeding $1 million the fee is $12,600.

This fee has remained the same now for four years in a row. The graph below shows these user fees from 2014 to 2024.

chart of user fees for 9100 relief

Tags: Authority - Revenue Procedures, Statistics