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Private Letter Rulings - Tax and Law Guidance

District Private Letter Rulings are the official tax positions of the Office of Tax and Revenue (OTR). The rulings are OTR's response to taxpayer requests for guidance on specific tax matters. A ruling may be relied upon by a taxpayer concerning a specific tax matter, since the ruling binds OTR as to the specific tax matter.
 
A ruling may be withdrawn or revoked or modified if the taxpayer's facts and circumstances change, the law changes or the ruling was issued in error. A ruling may not be used or cited as precedent. While a ruling is applicable solely to the taxpayer to which it is directed and may not be used by any other taxpayer, rulings provide guidance to other District taxpayers as to the interpretation and development of the DC Tax Code.
 
A ruling sunsets 10 years from the date of the ruling. The taxpayer may request that the ruling be extended after being reviewed by OTR.

How to Request a Private Letter Ruling

A taxpayer or their representative may request a private letter ruling by forwarding the following information to OTR:

  1. Taxpayer's name, business address and federal taxpayer identification number,
  2. Taxpayer's facts and circumstances concerning the specific tax matter for which the taxpayer is requesting guidance,
  3. Statutory or judicial authority upon which the taxpayer is relying,
  4. The relief requested, and
  5. A penalties of perjury statement signed and dated by the taxpayer with the following declaration:

"Under penalties of perjury, I declare that I have examined this request for a private letter ruling, including accompanying documents, and, to the best of my knowledge and belief, this request for a private letter ruling contains all the relevant facts relating to the request, and such facts are true, correct, and complete."

Requests should be sent to:

OTR Ruling Committee
Office of Tax and Revenue
1101 4th Street, SW, Suite W750
Washington, DC 20024

Please note that requests for rulings will not be accepted once the taxpayer has been contacted by OTR concerning the specific tax matter that is the subject of the ruling request.