The IRS allows taxpayers to submit ruling requests on the application of tax law to specific situations. The private letter ruling received from the IRS that addresses the issue can be relied on by the taxpayer (and only that taxpayer) as to the IRS' interpretation of the tax issue.
The IRS response time on a ruling request can at times be quite lengthy. This lengthy time often discourages taxpayers from making a request in the corporate area, since the taxpayer does not want to hold off on the planned transaction that long while waiting for the ruling.
In a helpful announcement, the IRS advised that it is beginning a pilot program to have letter rulings issued within 10 weeks of application in regard to Section 355 (corporate spin-off and split-off transactions) and Section 368 (corporate reorganization transactions).
Rev. Proc. 2005-68.
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