IRS PLR: Proposed Transaction Not Subject to Capital Gain, Loss Recognition; Related Rulings (IRC §355)

December 5, 2025, 10:14 PM UTC

The IRS has published a private letter ruling on I.R.C. §§355 and 368 regarding the recognition of capital gain or loss, if any, pursuant to a series of proposed transactions between related entities, and determining whether certain transactions constitute a reorganization. [PLR 202549011]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.

Learn more about Bloomberg Tax or Log In to keep reading:

See Breaking News in Context

From research to software to news, find what you need to stay ahead.

Already a subscriber?

Log in to keep reading or access research tools and resources.