Bar Group Urges IRS to Resume ‘Significant Issue’ Letter Rulings

The IRS should resume providing individual private letter rulings to taxpayers on “significant issues” within their corporate reorganizations and spinoffs, a bar group said Friday.

That would address taxpayers’ reluctance to seek PLRs for their transactions because of past back-and-forth over IRS guidance and fears that it will extend the timeline for seeking PLRs, the New York State Bar Association said in a report.

Significant-issue rulings deal with a specific aspect of a transaction rather than requiring that a ruling be about the entire transaction. The IRS had stopped providing such rulings as the result of guidance issued in ...