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A “letter ruling” is a written determination issued to a taxpayer by an Associate office in response to the taxpayer’s written inquiry, filed prior to the filing of returns or reports that are required by the tax laws, about its status for tax purposes or the tax effects of its acts or transactions.
A letter ruling interprets the tax laws and applies them to the taxpayer’s specific set of facts.
For purposes of this revenue procedure— (1) the term “Service” includes the four operating divisions of the Internal Revenue Service and the Associate offices.
This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).
A “determination letter” is a written determination issued by a Director that applies the principles and precedents previously announced by the Service to a specific set of facts.
It is issued only when a determination can be made based on clearly established rules in a statute, a tax treaty, the regulations, a conclusion in a revenue ruling, or an opinion or court decision that represents the position of the Service.