Expedited Letter Ruling Procedures for COVID-19

Taxpayers and tax practitioners impacted by the Coronavirus pandemic can request expedited letter ruling under Rev. Proc. 2020-1. The IRS normally processes requests for letter rulings in the order they were received, but taxpayers can have it expedited, if needed.

tax planning accountantThe request for expedited handling must be made in writing, preferably in a separate letter submitted with the letter ruling request. Requests should be submitted as promptly as possible after the taxpayer has become aware of the deadline or compelling business need.

Requests for expedited handling are granted at the discretion of the IRS and typically involve a factor outside of the taxpayer’s control that creates a real business need to obtain a letter ruling before a certain date in order to avoid serious business consequences. The COVID-19 pandemic is considered to be a factor outside of the taxpayer’s control that can support a request for expedited handling under Rev. Proc. 2020-1.

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