Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 77— MISCELLANEOUS PROVISIONS › § 7528
The IRS charges fees when you ask it for ruling letters, opinion letters, determination letters, and similar requests. Fees vary by category, reflect how long and hard each type of request is to handle, and must be paid up front. The law sets minimum average fees: $250 for employee plan rulings and opinions, $350 for exempt organization rulings, $300 for employee plan determinations, $275 for exempt organization determinations, and $200 for chief counsel rulings. Small employers get a break: no fee for a determination letter on a pension, profit-sharing, stock bonus, annuity, or employee stock ownership plan, as long as the request comes within roughly the plan's first five years and the employer has at least one participating worker who is not highly compensated. The fee for certifying a professional employer organization is an annual fee of up to $1,000 per year.
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Internal Revenue Code, Source: USLM XML via OLRC
Legislative History
Reference
Citation
26 U.S.C. § 7528
Title 26, Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73