As a partner at Jones Day in Washington DC, Lori Hellkamp provides creative solutions for complex tax challenges, utilizing a practical and commercial approach to problem-solving. Her practice spans corporate and international tax, M&A, and tax controversy matters. In addition, Lori has achieved favorable outcomes and much-needed certainty for clients by securing private letter rulings (PLRs) from the Internal Revenue Service (IRS).

The IRS issues a PLR to a taxpayer only when such taxpayer specifically requests guidance on one or more complex or uncommon tax situations. If granted, a PLR addresses only that taxpayer's unique circumstances -- it does not serve as a precedent for others. Because redacted versions of PLRs are made publicly available however, they can be helpful in illuminating the IRS's thinking on particular issues.

It is key to note that a PLR is specific to, and binding on, only the particular taxpayer requesting it. Since a PLR is not a precedent, the IRS is not obligated to apply the same approach or result to other taxpayers.