The goal of a private letter ruling is to remove any confusion and to advise the taxpayer, who is generally a company, on the tax treatment they may expect from the IRS based on the conditions mentioned in their opinion. These opinions are useful because they can resolve any questions that may arise regarding an individual's or company's tax situation. A private letter ruling is needed for anything that requires a specific interpretation of the law, such as: agreements between two companies, marital settlements, trusts, etc. A private letter ruling is also required when there is uncertainty about how the IRS will treat certain facts related to a particular case. Examples include: whether income is passive or active, self-employment taxes, dependency exemption rules, retirement plan requirements, eligibility for business deductions, application of the passive loss rule, computation of investment credits, eligibility for bonus depreciation, and more. These rulings can only be issued by staff members at the regional office of the IRS who have special authority to issue them. They can also only address issues that were raised by the taxpayer. If additional information becomes available after the fact, the IRS could determine that a previous ruling was incorrect and issue a new one. However, if the situation has changed significantly (such as due to court decisions), then it would be necessary to request a new private letter ruling.