IRS Issues New Guidance for Private Letter Rulings on Spinoffs

The IRS released new guidance on private letter rulings, detailing procedures for taxpayers seeking rulings on certain corporate transactions.

The agency’s Wednesday release of Revenue Procedure 2024-24 and accompanying Notice 2024-38 updates procedures to request private letter rulings on Section 355 transactions, which covers transactions such as spinoffs.

Private letter rulings let taxpayers request input from the IRS that interprets and applies tax laws to a specific issue.

The notice requests public feedback on Rev. Proc. 2024-24 and describes Treasury Department and IRS views and concerns relating to topics addressed in the revenue procedure.

The revenue procedure modifies and supersedes ...