Statements from Office of the Chief Counsel


Counsel Statement and Invitation for Public Comment on PLR User Fee Increase

January 4, 2021 — The Office of Chief Counsel has conducted its biennial review of the user fees for private letter rulings (PLRs) and other rulings contained in Rev. Proc. 2021-1, 2021-1 I.R.B. 1 (Jan. 4, 2021), in accordance with the requirements for setting such fees provided in IRC section 7528.

IRS request for information regarding the active trade or business requirement for section 355 separations of entrepreneurial ventures

May 6, 2019 — The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) have been studying whether, and to what extent, corporations may utilize the tax-free separation rules of section 355 of the Internal Revenue Code to separate established businesses from newer entrepreneurial ventures that have not collected income but have engaged in substantial research and development (R&D) and other activities.

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.

Statements from Office of the Chief Counsel Archive

Statements from Office of the Chief Counsel from 2017 and 2018.