Statements from Office of the Chief Counsel

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.

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.

Sept. 25, 2018 — The IRS is providing this statement to inform taxpayers and their advisers of a study regarding the active trade or business (ATB) requirement under section 355(b) of the Internal Revenue Code, to request comments on the matters under study, and to indicate that the IRS will entertain requests for private letter rulings as described below.

Oct. 13, 2017 — The Internal Revenue Service is providing this statement to inform taxpayers and their advisers of changes relating to requests for private letter rulings on certain corporate transactions.