- 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