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ARTICLE · 11 JULY 2013

IRS To Limit Some Corporate Private Letter Ruling Requests

Grant Thornton LLP
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The IRS announced in Rev. Proc. 2013-32 that it would restrict the scope of private letter rulings for Section 355 distributions, Section 332 liquidations, Section 351 exchanges, Section 368 reorganizations and Section 1036 recapitalizations.

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Grant Thornton'S Washington National Tax Office
Grant Thornton'S Washington National Tax Office
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The IRS announced in Rev. Proc. 2013-32 that it would restrict the scope of private letter rulings for Section 355 distributions, Section 332 liquidations, Section 351 exchanges, Section 368 reorganizations and Section 1036 recapitalizations, to try to conserve resources.

Taxpayers have until Aug. 23, 2013, to submit ruling requests. After that, the IRS will rule on only "significant issues" under Sections 332, 351, 355, 368 and 1036. The IRS defines a significant issue as an "issue of law the resolution of which is not essentially free from doubt and that is germane to determining the tax consequences of the transaction." That definition is a modification of the IRS's previous definition of a significant issue.

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