IRS Statement on Private Letter Ruling Pilot Program Extension

March 12, 2019

The Internal Revenue Service announced today that the pilot program for private letter rulings that address certain corporate stock distributions has been extended indefinitely.

In Rev. Proc. 2017-52, the IRS created the pilot program for taxpayers requesting rulings on whether corporate stock distributions, such as spin-offs, are tax-free under section 355 of the Internal Revenue Code. Participants in the program may obtain rulings on the general federal income tax consequences of these distributions and related transactions. The pilot program also includes procedures for ruling requests on these matters.

The pilot program was scheduled to expire on March 21, 2019, but it has been extended indefinitely. For further information, contact Lisa Fuller (202-317-7700).