IRS to Continue Issuing Section 355 Transactional Rulings

September/October 2019
Nebraska CPA
Read Time: Less than 1 minute

In March 2019, the IRS announced that the ruling program for section 355 distributions created under Rev. Proc. 2017-52 has been extended indefinitely. The ruling program expands the scope of letter rulings and offers taxpayers the opportunity to obtain a transactional ruling for corporate distributions intended to qualify as tax-free under section 355.

Due to section 355’s numerous statutory requirements and the inherent high stakes in
securing tax-free treatment for a section 355 distribution, taxpayers and practitioners were often hesitant to implement a section 355 distribution in the absence of a favorable IRS ruling. The ruling program allows taxpayers to obtain a transactional ruling and confidently implement a section 355 distribution.

For more information on the ruling process please read our article linked below. 

This content is made available for educational purposes only and to give you general information and a general understanding of the law, not to provide specific legal advice. By using this content, you understand there is no attorney-client relationship between you and the publisher. The content should not be used as a substitute for competent legal advice from a licensed professional attorney in your state.

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