IRS letter ruling - Reorganization to market bundled services, reduce costs 

January 24:  The IRS publicly issued a private letter ruling* concerning a cooperative’s proposed reorganization transactions in order to market bundled services to its customers on a cooperative basis, reduce its state sales and franchise taxes, and streamline management and accounting functions. PLR 201404004 (released January 24, 2014, and dated September 27, 2013).

Read PLR 201404004 [PDF 80 KB]


*Private letter rulings are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and can only be relied upon by the taxpayer to whom issued. It is important to note that, pursuant to section 6110(k)(3), such items cannot be used or cited as precedent. Nonetheless, such rulings can provide useful information about how the IRS may view certain issues.


The cooperative provides utility services for rural areas.



For more information, contact KPMG’s National Director of Cooperative Tax Services:


David Antoni, in Philadelphia

(267) 256-1627


Or Associate National Director of KPMG’s Cooperative Tax Services


Brett Huston, in Sacramento


(916) 554-1654




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