Louisiana Department of Revenue

How to Request a Private Letter Ruling

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Requests for private letter rulings (PLR) must be submitted in writing to:

Requests must be submitted by an identified taxpayer, or by the taxpayer's representative who has a power of attorney from the taxpayer. PLRs are not issued to tax practitioners who do not identify the clients for whom the rulings are sought.

Requests for PLRs must provide the following information:

• The name, address, and telephone number of the person requesting the private letter ruling;
• A power of attorney, if the person is represented by a third party;
• A statement of the specific questions to be answered or issues to be addressed in the private letter ruling;
• Citations to or copies of relevant statutes, regulations, court decisions, advisory opinions, or other authority that appear to support the position of the person requesting the ruling;
• A statement attesting:
  • Whether the person requesting the opinion has the same issue under audit or appeal with the department or with any other taxing or revenue authority;
  • If the person requesting the opinion has been notified that an examination or audit is pending;
  • If the person requesting the opinion is litigating the issues;
  • If the department, or any other taxing or revenue authority, has previously issued an advisory opinion on the subject matter discussed in the request for the private letter ruling (with copy attached);
  • If the Attorney General's Office has been, or will be, requested to issue an opinion concerning the issue, and
  • That prior to the issuance of a PLR, if the requesting person is notified of a pending examination or audit by the department or other taxing or revenue authority, they will notify the Secretary of the pending examination.