FEES FOR REQUESTS FOR RULING. DETERMINATION, AND SIMILAR LETTERS.

SEC. 10511. FEES FOR REQUESTS FOR RULING. DETERMINATION, AND SIMILAR LETTERS. (a) General Rule.— The Secretary of the Treasury or his delegate (hereinafter in this section referred to as the “Secretary”) shall establish a program requiring the payment of user fees for requests to the Internal Revenue Service for ruling letters, opinion letters, and determination letters and for similar requests. (b) Program Criteria.— (1) In general.— The fees charged under the program required by subsection (a)— 101 STAT. 1330–447 (A) shall vary according to categories (or subcategories) established by the Secretary, (B) shall be determined after taking into account the average time for (and difficulty of) complying with requests in each category (and subcategory), and (C) shall be payable in advance. (2) Exemptions, etc.— The Secretary shall provide for such exemptions (and reduced fees) under such program as he determines to be appropriate. (3) Average fee requirement.— The average fee charged under the program required by subsection (a) shall not be less than the amount determined under the following table: Category Average Fee Employee plan ruling and opinion $250 Exempt organization ruling $350 Employee plan determination $300 Exempt organization determination $275 Chief counsel ruling $200. (c) Application of Section.— Subsection (a) shall apply with respect to requests made on or after the 1st day of the second calendar month beginning after the date of the enactment of this Act and before September 30, 1990.