The LDR Tax Policy and Planning Division is here to address inquiries from taxpayers and tax professionals on matters of law and policy. Inquiries may be submitted to one of LDR’s tax policy inquiry email boxes.
Note: Question about the completion of returns or how to file should not be sent to these boxes.
Income and Franchise Taxes ([email protected])
Sales ([email protected])
Excise/Severance/Miscellaneous ([email protected])
How to Request a Private Letter Ruling
A Private Letter Ruling (PLR) is a written determination issued by the Louisiana Department of Revenue (the Department) to a specific taxpayer applying principles of law to the taxpayer’s particular facts and circumstances. A PLR does not have the force and effect of law and is not binding on any taxpayer. It is binding on the Department only with respect to the requesting taxpayer and only if the facts provided are complete, accurate, and the transaction is carried out as described. A PLR remains the Department’s position unless superseded by statute, regulation, court decision, or subsequent ruling.
PLRs are intended to address areas where the law is unclear and are not generally issued for procedural questions, hypothetical scenarios, or alternative fact patterns.
Before You Submit a Request
Requests must be submitted by an identified taxpayer or an authorized representative with a valid power of attorney.
Before submitting a request, taxpayers are encouraged to contact the Tax Policy and Planning Division at [email protected] to determine whether a PLR is appropriate.
Where to Submit
Requests may be submitted by email to: [email protected]
A PLR request must include all of the following:
- Name, address, and telephone number of the requesting taxpayer
- Power of attorney (if submitted by a representative)
- A clear statement of the specific questions or issues to be addressed
- A complete statement of all relevant facts
- Citations to or copies of relevant statutes, regulations, court decisions, administrative guidance, or other authority
- Copies of relevant supporting documents (e.g., contracts, invoices, agreements, reports)
- A signed statement addressing:
- Whether the issue is under audit, appeal, or litigation with the Department or another taxing authority
- Whether an audit or examination is pending or has been noticed
- Whether the issue is currently in litigation
- Whether a prior advisory opinion has been issued on the same issue (and a copy, if available)
- Whether an opinion has been or will be requested from the Louisiana Attorney General
- An agreement to notify the Department if a pending audit or examination is identified before issuance of the PLR
When a PLR May Be Issued
A PLR may be issued when:
- The request is submitted by an identified taxpayer or authorized representative; and
- The applicable law or guidance is unclear.
When a PLR Will Not Be Issued
A PLR will not be issued when:
- The law or regulations are clear
- Rulemaking under the Administrative Procedure Act is more appropriate
- The request is hypothetical or involves alternative scenarios
- The issue is under audit, appeal, or litigation (or likely to be)
- The request concerns federal tax issues unrelated to state conformity
- The request is incomplete
- The issue is better addressed through other guidance
- The request is withdrawn prior to issuance
