IRS May End Favorable Rulings on Some Corporate Transactions

Overview


Jay Singer was critical of a possible IRS move to reduce private letter rulings on corporate transactions, saying previous rulings “permitted taxpayers to look through dividends and other types of passive income earned by a member of a consolidated group to satisfy the gross receipts test.” Taxpayers in such instances have little legal authority to rely on “other than the many private letter rulings the IRS has issued previously,” Mr. Singer added.