Form 15662 – Guide to the IRS PLR Intake Form and Checklist

I remember the first time a plan sponsor asked me why their private letter ruling was dragging. We had the right facts, a clean legal theory, and good advisers. The holdup was not the substance, it was the intake, the attachments, and the back‑and‑forth that eats weeks.

If you have lived that pain, Form 15662 will feel like a breath of fresh air. It is the IRS’s proposed, standardized way to package Employee Plans PLR requests under Rev. Proc. 2025‑4 so you submit complete data in a format the Service can route, screen, and review faster. As of October 23, 2025, the comment window has closed, and the package is with OIRA for review, which signals real momentum toward adoption.

Key Takeaways

• Form 15662 standardizes how you present an Employee Plans PLR request under Rev. Proc. 2025‑4 using uniform, machine‑readable fields plus precisely labeled exhibits. Expect less rework when you submit a complete set.
• The IRS formally sought comments through August 15, 2025, and the information collection, including Form 15662, is now before OIRA under control number 1545‑1520. Status updates show the supporting package submitted in late September 2025.
• Rev. Proc. 2025‑1 continues to govern core submission mechanics for letter rulings, including pay.gov user fees, mailing and delivery options, and electronic correspondence by request. Build your 15662 workflow to those rules.
• Protect confidential business information with a redacted public version and a clear Exemption 4 basis, and remember that taxpayer identity items are protected return information under IRC section 6103.
• Practical path, map your facts to 15662, pre‑index exhibits, tie each issue to a user fee, and use a reviewer’s checklist to catch the small misses that cause big delays.

What is Form 15662 and Why It Matters

Form 15662 is a proposed intake form the IRS plans to use for Employee Plans Private Letter Rulings. Instead of bespoke cover letters and inconsistent exhibit lists, you complete structured fields for the petitioner, plan details, the issues presented, and the authorities you rely on, then attach labeled documents that match those fields. The aim is simple, fewer cycles between intake and technical reviewers, and faster routing to the right group. The IRS said the form would standardize the process without increasing burden, which is exactly what busy plan teams need.

Here is why it matters to you. PLR timing is often a function of completeness. A standardized format improves triage, cuts clarification emails, and lets you spend more time on the ruling question and less on administrative repairs. On the government side, machine‑readable fields improve tracking and assignment across Employee Plans, which is the piece of Counsel that handles these rulings under Rev. Proc. 2025‑4.

Treat Form 15662 like a structured brief. Give the IRS exactly what they need on page one, then prove it with clean, labeled exhibits.

Status Check, Where Things Stand Right Now

• The IRS published a Federal Register notice on June 16, 2025 inviting comments on “Procedures for Determination Letters and Other Rulings,” explicitly listing Rev. Proc. 2025‑4 and Form 15662, with comments due by August 15, 2025. That window is closed.
• OIRA received the updated information collection for Rev. Proc. 2025‑4 in late September 2025, including Form 15662 and a supporting statement. Watch that docket for approval and the final form.
• Meanwhile, your filing mechanics are still governed by Rev. Proc. 2025‑1, which specifies pay.gov for fees, paper submission addresses, hand delivery options, and the ability to use fax or encrypted email for certain correspondence if you request it.
• Note, some articles report “no added burden” and summarize how Form 15662 fits within Employee Plans processes. Those are useful orientation pieces, but your north star remains the IRS’s own notices and revenue procedures.

How Form 15662 Fits Within Rev. Proc. 2025‑4

Rev. Proc. 2025‑4 sets the Employee Plans procedures for PLRs. Form 15662 is the IRS’s way to bring those requirements into a common intake. You will map each required element, the facts, the discrete issues, the controlling authorities, and the supporting documents, to standardized fields and exhibit labels. The payoff, better predictability, faster docketing, and cleaner handoffs once the form is live.

Because Rev. Proc. 2025‑1 still controls addresses, fee payment, and correspondence protocols for letter rulings generally, you should design your 15662 checklist to mirror those mechanics. For example, pay the correct fee through pay.gov, include the receipt, and use the current mailing or hand delivery addresses. If you want encrypted email for follow‑up, ask for that up front.

What Changes In Your PLR Application Process

The biggest shift is structure. Instead of building a custom cover letter every time, you will complete a uniform questionnaire that forces you to identify the plan, pinpoint the governing provisions, state the issues, and provide exact citations to the Code, regulations, and guidance you rely on. Attachments will carry standardized names that match the fields in the form, which reduces guesswork for reviewers and reduces your revision cycles.

Expect two practical effects. First, intake correction loops should shrink because the form flags missing items early. Second, routing should speed up because the metadata in your submission tells the IRS which technical team owns the work. Early coverage from industry groups mirrors the IRS’s own summary, the goal is faster screening and more consistent packages, not new burdens.

If your team builds a repeatable 15662 kit now, you will win time later when the final hits. Map your documents, rehearse your numbering, and standardize the way you summarize facts and authorities.

Standardized Data Elements You Should Expect

While final line‑by‑line instructions will follow approval, the draft materials and the notice point to a few core elements you should prepare now.

• Petitioner identity and plan profile, including EIN, plan name, plan number, plan year end, and plan type.
• A short, precise issue statement for each ruling requested, paired with pinpoint Code and regulation citations.
• A concise facts‑and‑law summary that keeps narrative tight, then sends the details to labeled exhibits.
• Numeric items where relevant, such as contribution history or valuation dates for defined benefit plans.
• A clean exhibit index that ties each attachment to an issue and to a user fee entry.

Remember, your submission mechanics do not change until the IRS says so. Today, that means you still follow Rev. Proc. 2025‑1 for fee payments, paper addresses, and optional encrypted email or fax for follow‑up.

Timing, Review Workflow, And What Speeds Up

When a request arrives complete and consistent, intake can route it quickly. That is the promise of 15662. In plain terms, front‑loading machine‑readable data, clear exhibit labels, and per‑issue fees reduces preliminary screening time, which means fewer “please send X” emails and faster handoff to the technical reviewers who will analyze your questions. The IRS’s notice frames the form as standardization with no added burden, which supports this speed thesis.

Short term, expect an adjustment period. Your team will need to align templates and train on new fields. The IRS will calibrate systems and instructions. After that, the cycle should settle into a steadier rhythm, with more time on substance and less on packaging.

Costs And Administrative Burden

No one loves paying user fees or spending hours on assembly. The good news, a standard intake usually cuts assembly time. Many plan teams find that a structured intake reduces admin time by double‑digit percentages because checklists and field‑to‑exhibit mapping eliminate guesswork. The government’s framing is consistent with that experience, consolidate inputs, reduce variability, and keep burden neutral from a regulatory standpoint.

What to do now so costs actually drop:

• Map your legacy PLR templates to draft 15662 fields and exhibit names.
• Pilot the format on one or two live matters to surface gaps.
• Track your hours by category, setup versus analysis, to confirm you are freeing time for substance.

Submission Mechanics You Still Need To Follow

Even with a new intake form coming, your process must line up with Rev. Proc. 2025‑1, which is the annual backbone for letter ruling submissions. That means:

• Pay the correct user fee through pay.gov and include the receipt.
• Use the current postal or hand delivery addresses, and mark the package as a ruling request submission.
• If you prefer, request that follow‑up documents and even the ruling be provided by fax or encrypted email, since the Service generally honors reasonable requests for the form of correspondence.

Note, the IRS corrected certain user fees in a January 2025 revenue procedure. Always confirm the current fee table before you submit, since the numbers can change and the IRS will return underpaid packages.

Confidentiality, Privacy, And Public Disclosure

There are two pillars to keep straight. First, taxpayer identity and return information are protected by law under IRC section 6103. Second, some of what you submit may still be releasable in some form, and that is where FOIA comes in, especially Exemption 4 for trade secrets and confidential commercial information. Build your package assuming both pillars matter.

What The IRS Discloses And What It Protects

• Taxpayer‑identifying information is protected return information under section 6103. Expect the Service to withhold it unless you consent.
• For commercial or financial information, FOIA Exemption 4 can protect materials that are confidential in the ordinary sense after the Supreme Court’s Argus Leader decision. Agencies are guided to ask whether the submitter keeps it private and whether there was an assurance of confidentiality.

Practical move, submit both an unredacted set and a carefully redacted public version with page and line mapping. State your Exemption 4 basis in plain language, not just labels.

Protecting Taxpayer Information In Practice

Check the box for IRC 6103 treatment where applicable, keep names, addresses, EINs, and similar identifiers out of the public set, and make sure your redactions preserve context so a reviewer can still follow the story. If you want the Service to keep narrative analysis nonpublic, you need a real legal basis, for example trade secret or privileged commercial information. Routine legal theories rarely qualify.

Managing Sensitive Attachments Without Slowing The Case

• Label every attachment and pair each one with a redacted version.
• Use secure transmission, paper package or encrypted files through an authenticated channel the IRS accepts, and note your method in the cover letter.
• Keep a privilege log and a clean chain of custody in your file so you can answer any challenge later.

Coordinating Form 15662 With User Fees And Exhibits

Tie each issue to a fee entry and to a labeled exhibit. That one‑to‑one linkage is your best friend in review. Confirm your fee category in the current fee table and include either the check or the pay.gov receipt per the revenue procedure. Then use a short, readable cover letter that lists the issues, cites the relevant sections of Rev. Proc. 2025‑4, and cross‑references your exhibit index. Add Form 2848 if you want a representative to receive correspondence.

Common misses that lead to rejection, wrong fee amount, missing receipt, plan identifiers off by one digit, or exhibit labels that do not match your index. A five‑minute cross‑check saves you weeks.

Quick gut check before you seal the packet, do the fee entries, exhibit labels, and issue statements match line for line?

Common Pitfalls And How To Avoid Rejections

The fastest rejections come from simple misses. Here is a tight checklist you can copy into your process.

• Signature method, follow the instructions exactly, including penalties of perjury statements where required. If a power of attorney signs, include Form 2848 and the signed statement the procedure calls for.
• Identifiers, use the legal plan name, the nine‑digit EIN, the three‑digit plan number, and the correct plan year end.
• Fees, confirm the category, amount, and payee. Include the pay.gov receipt if you paid online.
• Attachments, index and paginate, align labels to the form’s fields, and include governing plan and trust documents plus any actuarial or valuation reports you reference.
• Delivery, use the current mailing or hand delivery address and keep proof of delivery. Request encrypted email or fax for follow‑up if that helps your team move faster.

Practical Tips For Taxpayers And Advisors

Think like a reviewer. You want them to understand your question quickly, then verify your support easily.

• Frame precise questions and, where helpful, propose draft ruling language.
• Anchor each issue with a short facts‑and‑law summary and push detail to labeled exhibits.
• Quantify dates and amounts so routing teams can assign the right specialists.
• Separate background from material facts, and keep narrative tight.

If you build your kit now, you will be ready when the form goes final. As of late September 2025, the OIRA docket includes Form 15662 and supporting materials, so final instructions could follow OMB approval.

Opportunities To Engage With The IRS

The formal comment period closed on August 15, 2025. If you did not submit, there is still value in documenting your suggestions and edge cases for internal use. You can move quickly when FAQs or revised instructions appear, and you can align with industry groups that continue to meet with the IRS on implementation topics. For the official record of what the IRS asked for and how to contact them, keep a copy of the June 16, 2025 notice.

Anticipated Timeline And What To Watch

While dates can move, you can plan around three milestones.

• Public comment deadline passed on August 15, 2025.
• OIRA received the collection in late September 2025 and posted supporting materials. Watch for approval, then for IRS posting of the final form and instructions.
• After approval, expect an IRS notice with the form, instructions, and any transition window. Continue to follow Rev. Proc. 2025‑1 for submission mechanics until the Service updates procedures.

Quick Reference Table

Phase	What to watch	Why it matters
Comment period	Ended August 15, 2025	Baseline for changes in the final version.
OIRA review	ICR 1545‑1520 received late September 2025	Signals pending approval and release timing.
Final release	IRS posts form and instructions	Triggers your internal rollout and training.

Preparing Stakeholder Actions

You can stand up a light, practical rollout in four phases.

Phase	Priority actions	Owner
Discover	Inventory pending PLRs, run a gap analysis against draft 15662 fields	Legal and Tax
Design	Create templates and an approvals map, define exhibit naming rules	Compliance
Enable	Train preparers and reviewers, configure tools for numbering and version control	HR and IT
Execute	Pilot on a small case, refine checklists, measure time saved	PMO and Leads

Where Accountably Fits, Only If You Need Help

If you are already resourced and structured, run with it. If you need predictable capacity to standardize workpapers, index exhibits, and protect review time during peak season, Accountably can integrate trained offshore teams into your workflow under your tools and templates. The focus is control, not staffing, so you maintain quality, security, and review discipline while you scale PLR prep and related compliance work. Use us as a delivery system, not a band‑aid.

• SOP‑driven execution across bookkeeping, tax, and month‑end work that feeds your PLR exhibits
• Structured workpapers and version control that cut reviewer time
• Turnaround SLAs and escalation paths so deadlines stop slipping

If that kind of support would help you hit your dates, we can align a model that fits your stage of growth.

FAQs About Form 15662 And PLRs

Is Form 15662 final?

Not yet. The IRS requested comments by August 15, 2025 and the information collection package, which includes Form 15662, is with OIRA for review under control number 1545‑1520. Watch the docket and IRS.gov for the approved form and instructions.

Does Form 15662 replace Rev. Proc. 2025‑1 or 2025‑4?

No. Form 15662 standardizes intake for Employee Plans PLRs within the framework of Rev. Proc. 2025‑4. You still follow Rev. Proc. 2025‑1 for fee payment, addresses, and correspondence mechanics until the IRS says otherwise.

Can I submit a PLR entirely electronically?

As of January 2025, the procedure provides for pay.gov fee payments and allows fax or encrypted email for certain correspondence if you request it. Initial submissions have established paper and hand delivery channels, so confirm mechanics in the latest revenue procedure and any IRS updates that accompany the final 15662.

How should I handle confidential business information in my exhibits?

Provide an unredacted set and a redacted public version that maps every redaction by page and line. Cite FOIA Exemption 4 where appropriate and remember that taxpayer identity and return information are protected by IRC section 6103.

Where do I find the current user fee?

Check the fee table associated with the current year’s revenue procedures. The IRS corrected certain fees in early 2025, so verify the number before you submit and include the pay.gov receipt or payment with your package.

A Simple, Repeatable Checklist You Can Use

• Define each issue in one or two sentences with pinpoint citations.
• Draft a tight facts‑and‑law summary.
• Build an exhibit index that ties each issue to one or more documents and to a user fee line.
• Label exhibits precisely and follow a consistent naming convention.
• Validate plan identifiers, dates, and amounts.
• Cross‑check fee category and include the pay.gov receipt.
• Prepare a redacted public version and explain any Exemption 4 claims.
• Include Form 2848 if you want representatives to receive correspondence.
• Request encrypted email or fax for follow‑up if that helps.

Conclusion

Form 15662 is about clarity, speed, and fewer detours. If you treat it like a structured brief, you will make the reviewer’s job easier, which usually makes your life easier. The IRS has set the table, a standardized intake that maps to the Employee Plans procedures and does not add regulatory burden. Your job is to build a kit that fills the fields cleanly, labels the exhibits clearly, and aligns fees and redactions the first time. As of today, the comment period is over and the form is in OIRA’s hands. Get your templates and checklists ready so you can move on day one of the final.