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2026 PLR Fees For 9100 Relief Remain the Same

2025-12-26

Today the IRS released Rev. Proc. 2026-1. 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 (small, medium, and large), the user fee remained the same.

  • Small Taxpayers: For taxpayers with gross income under $400,000, the fee is remains at $3,450.
  • Medium-Sized Taxpayers: For taxpayers with gross income greater than $400,000 and less than $10 million, the fee is remains at $9,775.
  • Large Taxpayers: For taxpayers with gross income exceeding $10 million the fee is remains at $14,500.

The new user fees are effective as of January 30, 2026. The graph below shows the user fees from 2014 to 2026.

PLR Fees Up Through 2026

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