The Internal Revenue Service (IRS) today issued Revenue Procedure 2020-29, which permits and instructs taxpayers on the electronic submission of requests for private letter rulings (PLRs) and other advice from the Associate Chief Counsel Offices and the Large Business and International (LB&I) Division. 

The guidance issued today temporarily allows for the electronic submission of requests for letter rulings, closing agreements, determination letters, and information letters. It includes certain security requirements for electronic signatures and a declaration that must be signed and submitted acknowledging the risks inherent in sending confidential information via email.

The following IRS offices are covered by the new submission policies:

• Associate Chief Counsel (Corporate);
• Associate Chief Counsel (Financial Institutions and Products);
• Associate Chief Counsel (Income Tax and Accounting);
• Associate Chief Counsel (International);
• Associate Chief Counsel (Passthroughs and Special Industries);
• Associate Chief Counsel (Procedure and Administration); and 
• Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).

​The procedures for determination letters issued by the IRS's Small Business/Self Employed Division, Wage and Investment Division, and the Tax Exempt and Government Entities Division are excluded from today's guidance. 

The IRS says it will continue to accept advice requests sent via regular mail and private delivery but warns that staffing restraints are likely to cause processing delays for paper submissions.  

The nine-page text of Revenue Procedure 2020-29 is posted here.

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