IRS extends private letter ruling pilot program for corporations

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The Internal Revenue Service has indefinitely extended a pilot program for private letter rulings for corporate taxpayers.

The IRS originally created the pilot program in 2017, announcing it in a 2017 revenue ruling that year. It was aimed at taxpayers requesting rulings on whether corporate stock distributions, such as spin-offs, are tax-free under section 355 of the Internal Revenue Code. Participants in the program have been able to get rulings from the IRS on the general federal income tax consequences of these distributions and related transactions. The pilot program also includes procedures for ruling requests on these matters.

The pilot program was originally scheduled to expire on March 21, 2019, but the IRS’s Office of the Chief Counsel said Tuesday that the pilot program has been extended indefinitely. The Senate confirmed Michael Desmond late last month as the IRS's new chief counsel (see Senate confirms new IRS chief counsel).

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