Estate Tax Closing Letter Fee Rises from $56 to $76: What Executors Should Check Before Requesting Letter 627 Under T.D. 10055 (Effective October 26, 2026)

Bottom line

Final regulations T.D. 10055 (91 FR 60801, published September 25, 2026) took effect on October 26, 2026. For estate tax closing letter (IRS Letter 627) requests the IRS receives after October 26, 2026, the user fee rises from $56 to $76 per request. This affects executors, and their representatives, who filed Form 706 or Form 706-NA and plan to ask the IRS for a closing letter. The increase is small, but closing letters are issued only on request, the fee is generally not refunded, and a supplemental return means paying again. Before you request one, check the estate's account transcript for TC 421.

News background

The estate tax closing letter (Letter 627) tells the executor that the IRS accepted the estate tax return as filed or that the examination is complete. For estate tax returns filed on or after June 1, 2015, the IRS issues closing letters only on request. In 2021, T.D. 9957 set the first user fee, $67, effective October 28, 2021. From May 21, 2025, T.D. 10031 (an interim final rule) cut the fee to $56, and T.D. 10038 finalized it on December 1, 2025.

Under the Independent Offices Appropriations Act (31 U.S.C. 9701) and OMB Circular A-25, the IRS reviews user fees every two years and charges the full cost of the service. On June 2, 2026, Treasury and the IRS proposed raising the fee to $76 in REG-103193-26 (91 FR 32909). They received one public comment. On September 25, 2026, T.D. 10055 adopted the proposed text without change. It amends 26 CFR §300.12: paragraph (b) sets the fee at $76, and paragraph (d) applies it to requests the IRS receives after October 26, 2026. Sources: Federal Register document 2026-19666 and the IRS pages "Frequently asked questions on the Estate Tax Closing Letter" and "Transcripts in lieu of estate tax closing letters."

Old vs. new

Fee per request: Old: $56 from May 21, 2025. New: $76 for requests the IRS receives after October 26, 2026.

Legal basis: Old: T.D. 10031 and T.D. 10038. New: T.D. 10055 (finalizing REG-103193-26), 26 CFR §300.12(b) and (d).

How to request (unchanged): On Pay.gov, search for "Estate Tax Closing Letter User Fee." You can pay by bank account (ACH), PayPal, Venmo, or a debit or credit card (UnionPay is accepted). You do not need a Pay.gov account.

When to request (unchanged): If you have confirmed TC 421 on the account transcript, you can request at any time. Otherwise, wait at least 9 months after filing Form 706 or Form 706-NA. If the return was examined, wait at least 30 days after the examination closes.

Who receives the letter (unchanged): Only the executor at the address on Form 706, lines 6a and 6b (Form 706-NA, lines 9a and 9b), plus representatives authorized on Form 2848 or Form 8821. The address you type into Pay.gov is not used.

Refunds and duplicate requests (unchanged): Early requests, duplicate requests and requests after a supplemental or amended return are generally not refunded. If you want a new closing letter after a supplemental or amended return, you pay a separate fee.

Alternative (unchanged): Under Notice 2017-12, an estate tax account transcript can be used instead of a closing letter. Authorized tax professionals can pull it instantly through the Transcript Delivery System (TDS), and executors can request a mailed copy on Form 4506-T. TC 421 on the transcript means the return was accepted as filed or the examination is complete, and the transcript does not carry this user fee.

Self-check

If you are an executor who filed Form 706 and is about to distribute assets or close the estate: ask whether the beneficiaries, bank or attorney really need Letter 627, or whether an account transcript showing TC 421 is enough. If you do need the letter, budget $76.

If you paid $56 on Pay.gov before October 26, 2026: under T.D. 10055's applicability rule, the new fee applies only to requests received after October 26, so a request already submitted generally does not owe the difference. Don't submit again "just to be sure." Duplicate requests are generally not refunded.

If you filed Form 706 only to pass a deceased spouse's unused exclusion (DSUE, portability) to the surviving spouse: a closing letter is not required, but it is still worth tracking the examination window and TC 421. The 2026 basic exclusion amount is $15,000,000.

If the person who died was neither a U.S. citizen nor a U.S. resident (for example, a parent in China) and left a U.S. bank or brokerage account: a closing letter is not a transfer certificate. U.S. financial institutions generally look for a transfer certificate before releasing assets, and it is a separate IRS request. Estates with more than $60,000 of U.S.-situated assets generally must file Form 706-NA.

If you are a co-executor but not the executor named on Form 706, line 6a: the IRS will not mail the closing letter to you. First file Form 56 and Form 8822 to update the estate's address of record (allow 4 to 6 weeks), then make the request.

Simplified example

This is a simplified example to illustrate the process and fees. It is not an IRS conclusion for any specific case.

Mr. Chen, a U.S. tax resident, died on August 12, 2025. His estate was below the filing threshold, but to pass his unused exclusion to his wife, the executor (his son) filed Form 706 on May 4, 2026. The due date was May 12, 2026.

1. Timing: As of October 27, 2026, the son has not seen TC 421 on the account transcript. Without TC 421, IRS guidance says to wait at least 9 months after filing, so he should request the closing letter on or after Thursday, February 4, 2027. An earlier request would still be accepted, but the letter would not go out until TC 421 posts, and the fee would not be refunded.

2. Fee: A February 2027 request costs $76, which is $20 more than the old $56. If he later finds a missed asset and files a supplemental return, a new closing letter costs another $76, or $152 in total.

3. A simpler path: A CPA with a Form 2848 on file can pull the account transcript through TDS. Once TC 421 appears, the family can check whether the beneficiaries or financial institutions will accept the transcript. If they will, there is no need to request a closing letter.

4. Status check: If he requests on February 4, 2027 and still has no letter after 120 days (June 4, 2027), the executor can call the IRS at 866-699-4083 with the Pay.gov transaction date and Tracking ID ready.

Action steps and timeline

Now (from October 26, 2026): Budget $76 for new requests. Pull the account transcript first to see whether TC 421 has posted, so you don't request too early.

Before you request: Confirm the executor's address on Form 706, lines 6a and 6b (Form 706-NA, lines 9a and 9b) is still current. If it changed, file Form 8822 first and allow 4 to 6 weeks. Representatives should confirm their Form 2848 or 8821 is recorded on the IRS CAF system.

When you request: Use only the official Pay.gov page, check the acknowledgment box, and save the confirmation email and Tracking ID. Do not submit twice for the same return.

After you request: The IRS typically researches a request within about three weeks. If TC 421 has not posted, it rechecks about every 60 days. If 120 days have passed since the request (and at least 9 months since filing) with no letter, call 866-699-4083.

Estates of nonresidents who were not U.S. citizens: Plan the transfer certificate request at the same time (fax a copy of Form 706-NA, or an affidavit and supporting documents, as the IRS instructs). The IRS says affidavit-based requests take 12 to 18 months.

Later: Under OMB Circular A-25, the IRS reviews this fee every two years, so it may change again. Check the amount the IRS posts at the time you request.

How YCL can help

Estate tax returns: We prepare Form 706 and Form 706-NA and handle portability (DSUE) elections, late elections under Rev. Proc. 2022-32 and supplemental filings.

Closing status tracking: With a Form 2848, we pull the estate's account transcript through TDS, confirm TC 421 and assess whether you still need Letter 627, so you don't pay the fee unnecessarily.

Closing letter requests: We check executor and representative addresses, handle Form 56 and Form 8822 updates, keep the Pay.gov records and follow up under the IRS process.

Cross-border estates: When a parent in China leaves U.S. assets, we help determine the Form 706-NA filing requirement and which assets count as U.S.-situated, assist with the transfer certificate, and coordinate beneficiaries' Form 3520 reporting. Related article: https://yclcpa.com/en/insights/estate-tax-form-706-na-nonresidents

YCL Accounting & Consulting is a multistate CPA firm serving clients nationwide, in English and Chinese.

FAQ

Q: How much does an estate tax closing letter cost now?

A: $76 per request for requests the IRS receives after October 26, 2026 (T.D. 10055). Earlier requests were $56.

Q: Do I have to request a closing letter?

A: No. The IRS says an estate tax account transcript can be used instead, and TC 421 on the transcript means the return was accepted as filed or the examination is complete. Whether that is enough depends on what the beneficiaries, attorney or financial institution require.

Q: If I request too early on Pay.gov, will I get a refund?

A: Generally, no. If you request before TC 421 posts, the IRS waits until it posts to issue the letter and does not refund the fee. Duplicate requests and requests after a supplemental return also each need their own fee.

Q: My parent in China left U.S. assets. Is a closing letter enough to transfer them?

A: No. A closing letter is not a transfer certificate. For the estate of a nonresident who was not a U.S. citizen, U.S. financial institutions generally look for a transfer certificate before releasing assets, and you request it from the IRS separately.

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Disclaimer

This article is general tax information only and is not tax, legal or investment advice for any person or business. It does not promise any tax result or IRS position. It is based on T.D. 10055 (91 FR 60801), published in the Federal Register on September 25, 2026; proposed regulations REG-103193-26 (91 FR 32909) of June 2, 2026; and the IRS pages on the estate tax closing letter, transcripts in lieu of closing letters, and transfer certificates for nonresident estates. IRS processing times and fees may change. Check the latest IRS guidance and consult a licensed tax professional about your situation.