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Is Nothing Free? Estate Tax Closing Letters Will Now Cost You

October 13, 2021 (3 min read)

IRS and Treasury released final regulations that establish a new user fee of $67 for persons requesting the issuance of an estate tax closing letter (formerly known as IRS Letter 627). The final regulations adopt, without significant change, proposed regulations issued in late December 2020. 85 Fed. Reg. 86,871 (Dec. 31, 2020). The IRS and Treasury justify charging estates $67 to cover such letters’ costs, because issuing the letters qualifies as a service providing a special benefit to estates. Although obtaining a closing letter from the IRS can be beneficial to an executor of an estate, it is also a legal requirement. The IRS said it would begin charging the fee on October 28, 2021. Closing letter requests must be made using Pay.gov. 86 Fed. Reg. 53,539 (Sept. 28, 2021).

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Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.  

  • Tax Key Legal Developments Tracker (Federal)
    Stay informed on new developments.
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      IRS issues final regulations under I.R.C. Sections 250 and 951A addressing the calculation of qualified business asset investment (QBAI) for qualified improvement property (“QIP”) under the alternative depreciation system (ADS). TD 9956 also contains final regulations with transition rules relating to the impact on loss accounts of net operating loss (NOL) carrybacks allowed by reason of the CARES Act. The final regulations affect U.S. shareholders of CFCs (domestic corporations eligible for the section 250 deduction) and taxpayers that claim credits or deductions for foreign income taxes. 86 Fed. Reg. 52,971 (Sept. 24, 2021).
    • International Tax
      The IRS updates countries on Tax Data Exchange List under Treas. Regs. §§ 1.6049-4(b)(5) and 1.6049-8(a). Rev. Proc. 2021-32.


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