News & Analysis as of

Distribution Rules Private Letter Rulings

King & Spalding

Compensation and Benefits Insights - September 2018

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The IRS recently updated its two model safe harbor explanations that can be used to satisfy the requirement under Section 402(f) to provide notices setting forth certain information to participants who are eligible for...more

Troutman Pepper

New Private Letter Ruling Pilot Program - Focus on Spin-Off Transactions - Tax Update Volume 2017, Issue 6

Troutman Pepper on

In a new 18-month pilot program, the IRS is temporarily opening up a previous no-rule policy with respect to certain issues arising in a distribution by a corporation to its shareholders under Section 355....more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Weintraub Tobin

Holiday Horror Series: Part 2- Hectic Holiday Rollovers

Weintraub Tobin on

With the holidays upon us, we all can relate to how easy it is to mistakenly overlook important things amidst the cheery holiday hustle and bustle: leaving the Christmas ham in the oven a few hours too long, forgetting to...more

Snell & Wilmer

IRS Makes Late Rollovers Easier

Snell & Wilmer on

Generally, distributions from a qualified retirement plan that are eligible for rollover must be rolled over within 60 days of the date on which the distribution occurs. If a taxpayer did not complete the rollover within 60...more

BCLP

I Know My Rollover is Late, but It’s Okay. Trust Me.

BCLP on

As retirement plan professionals know, certain distributions from plans and IRAs to taxpayers can be rolled over to another plan or IRA within 60 days. Of course, sometimes 60 days is just not enough and the IRS recognizes...more

Bradley Arant Boult Cummings LLP

New Self-Certification Procedure for Late Rollovers

The Internal Revenue Service (IRS) has issued Revenue Procedure 2016-47, which provides for a new self-certification procedure for participants who receive retirement plan distributions but inadvertently miss the 60-day time...more

Morrison & Foerster LLP

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

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