IRS release on expedited request for letter rulings (COVID-19)

IRS release on expedited request for letter rulings

The IRS today—in a release reminding taxpayers of the availability of expedited requests for letter rulings—noted that the coronavirus (COVID-19) pandemic is a “factor outside of the taxpayer’s control” and as such can support a request for expedited handling under Rev. Proc. 2020-1.


The IRS release—IR-2020-212—explains that under Rev. Proc. 2020-1, the IRS ordinarily processes requests for letter rulings in the order that they are received, but that a taxpayer with a compelling need to have a request processed more quickly may request expedited handling.

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

© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us