IRS Looks to Update Guidance for PLRs on Tax-Free Spinoffs

The IRS plans to update guidance for companies asking for private letter rulings on tax-free spinoffs, an official said.

The agency will “update and supersede” Revenue Procedure 2018-53, which lays out guidance for companies seeking rulings on the transactions, said Mark Schneider, special counsel to the agency’s Associate Chief Counsel (Corporate).

There is no timing set for the update, but “it’s a high priority,” he said.

• The revenue procedure addresses PLR requests concerning tax-free spinoffs in which a bank buys parent company debt from a third party and then transfers it to the parent in exchange for ...