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Why Corporations Don't File State Tax Private Letter Rulings

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  • Taxpayers must disclose their identify before obtaining an answer from the state.
  • Facts may not be accurate, or disputed later, making the answer invalid.
  • Ruling may be revoked at any time.
  • Timing of the proposed and prospective transaction with obtaining an answer from the state.
  • Rulings are binding unless the facts are not accurate.
  • Unsure as to how deep of an analysis of the law the corporation is required to provide.
  • The length of time to obtain a ruling.

Why would you request a private letter ruling?

  • To avoid receiving an assessment for additional tax, interest and penalties in the future

How do you file a private letter ruling?

  • get your facts straight
  • do it timely

Any questions?

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