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Corporate Taxes Federal Pilot Programs Private Letter Rulings

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Jones Day

IRS Opens Pilot Program on Tax-free Spin-offs

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The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more

A&O Shearman

IRS Expands Scope of Spin-Off Private Letter Rulings in 18-Month Pilot Program

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On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more

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