IRS Pilot Expands Corporate Private Letter Ruling Program - McDermott Will & Emery

IRS Pilot Expands Corporate Private Letter Ruling Program

Overview


Jay Singer said that in Rev. Proc. 2017-52, the IRS makes it clear that there are circumstances in a corporate spinoff where the agency should look at an entire transaction rather than just isolated issues. But, Mr. Singer added, the agency also tries to strike a balance in advising taxpayers not to go overboard with their requests.