As an aside since you mentioned a PLR (Private Letter Ruling) - do you know that PLR's require a tax attorney that can cost $5-$10 thousand dollars and the PLR filing fees (that vary, but ) can be as much a $30,000 for 2019?
So if you want a PLR, be prepared to spend between $10,000-$50,000 to obtain one and then it might not be in your favor.
**Disclaimer: This post is for discussion purposes only and is NOT tax advice. The author takes no responsibility for the accuracy of any information in this post.**
