The IRS has increased the fees for many private letter rulings, with new prices taking effect in early February.

Appendix A of Internal Revenue Bulletin: 2021-1 lists the fee schedule. User fees that are not changing are requests for a determination letter from a director ($275), requests for a Foreign Insurance Excise Tax Waiver Agreement ($8,000), and substantially identical letter ruling requests in the case of § 25(c)(2)(B) ($1,500), pre-filing agreements ($181,500), requesting competent authority assistance under tax treaties ($37,000), statements of value for 1-3 items ($7,500) and costs for additional items beyond three ($400 per). Users seeking a request for an advance pricing agreement or a renewal of an advance pricing agreement need to consult Section 3.05 of Rev. Proc. 2015-41, 2015-35 I.R.B. 263.

Getting slightly cheaper are requests to use a fiscal year based on a business purpose ($6,200 to $5,000), requests for extensions of time to file Form 1128 ($6,500 to $5,300), and applications to adopt, change, or retain a tax year ($6,200 to $5,000).

The remainder of items have become more expensive, sometimes by a lot. Requests for closing agreements on a proposed transaction or on a completed transaction before a return for the transaction has been filed in which a letter ruling on that transaction is not requested or issued, for instance, have gone from $30,000 to $38,000.