The IRS has released Revenue Procedure 2017-52, which introduces an 18-month pilot program to accept letter ruling requests addressing the general federal income tax consequences of transactions intended to qualify as tax-free stock distributions.
This rev proc introduces the program expanding the scope of letter rulings available from the IRS to include for a period of time rulings on the tax consequences of a distribution of stock, or stock and securities, of a controlled corporation under § 355 of the IRC.
It provides procedures for taxpayers requesting these rulings, and clarifies procedures for taxpayers requesting rulings on significant issues relating to these transactions.
Rev. Proc. 2017-52 will be in IRB 2017-41, dated Oct. 10.
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