You are a tax accountant in a public accounting firm and the tax partner comes to you with the following request:
Please draft a 300 word memo that explains to one of the firm’s clients why it is advisable to file a private letter ruling (PLR) request for a proposed transaction that the client is planning to execute. In your memo note the following:
- procedure for requesting the PLR
- effect of the PLR on the client
- benefits for the client associated with obtaining the PLR