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A private letter ruling is a written statement issued by the Louisiana Department of Revenue (LDR) to a taxpayer applying principles of law to the taxpayer’s specific set of facts. This type of policy statement is only issued if there is no other guidance that addresses the correct application of the legal principles to the taxpayer’s particular situation.
When making a private letter ruling request, the taxpayer must explain their specific situation, facts, and questions and then present their legal analysis and interpretation of the correct tax treatment. The private letter ruling will agree or disagree with the taxpayer’s analysis and proposed tax treatment and explain the reasons for the ruling. Private letter rulings are not generally appropriate for questions of procedure.
Before making a private letter ruling request, it is recommended that the taxpayer contact the Policy Services Division at 225-219-2780 or by email at email@example.com to discuss whether a private letter ruling is appropriate for the situation. If a private letter ruling is inappropriate, other guidance can be given before the taxpayer invests the significant effort required to prepare a request.
Once it is determined that a private letter ruling is appropriate, the request must be submitted to the Policy Services Division by email at firstname.lastname@example.org or by mail to the following address:
Requests must be submitted by an identified taxpayer or by the taxpayer's representative who has a power of attorney from the taxpayer. Private letter rulings will not be issued to tax practitioners who do not identify the client for whom the ruling is sought.
Requests for private letter rulings must provide the following information:
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