IRS announces end of moratorium on MLP letter ruling requests.

The IRS has resumed the ruling process for private letter ruling (PLR) requests regarding qualifying income issues for MLPs under section 7704. An official of the IRS Office of Associate Chief Counsel (Passthroughs and Special Industries) announced the end of its moratorium on such PLR requests at the Federal Bar Association Section on Taxation annual meeting in Washington on March 6, 2015.

While the PLR process has restarted, the IRS cautioned taxpayers with pending qualifying income PLR requests that some time will be required to process the requests. The IRS “expects to work diligently to process” the pending qualifying income PLR requests but has not provided a specific timeline for clearing the existing backlog.