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Income Taxes › Private Letter Rulings

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Eversheds Sutherland (US) LLP

A fickle friend: Released on the same day, IRS rulings grant and deny 9100 relief

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On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

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On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Freeman Law

S-Corporations | Involuntary Termination of the S-Election

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Private Letter Ruling 202302004, 01/13/2023, IRC Sec. 1362 - Summary: Entity “A” (“A”) was incorporated as a limited liability company under state law and thus was initially treated as a partnership for federal income tax...more

Freeman Law

Obtaining Extension to Make §754 Election

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Private Letter Ruling 202244002, November 4, 2022 - In a recent Private Letter Ruling, the Internal Revenue Service granted a partnership 120 days from the date of the letter to make an election under §754 of the Internal...more

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

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Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

Freeman Law

That’s Not Income! | REIT’s Section 481(a) Adjustments Not Considered Gross Income

Freeman Law on

Mark Twain once said, “Buy land, they’re not making it anymore.” Perhaps it is this sentiment (along with returns on investments) that has led to the popularity of real estate investment trusts...more

Freeman Law

How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.

Freeman Law on

IRS Private Letter Ruling 202226008, 07/01/2022: A foreign purchaser bought all the stock of a foreign target (controlled foreign corporation) which was a qualified stock purchase under 26 U.S.C. Section 338(d)(3). The...more

Troutman Pepper

IRS Issues Private Letter Ruling on Plain Vanilla Preferred Stock

Troutman Pepper on

Plain vanilla preferred corporate stock has two significant consequences for federal income tax purposes. Ownership of plain vanilla preferred stock is not included in measuring owner shifts of loss corporations under Section...more

McDermott Will & Emery

Weekly IRS Roundup March 27 – April 2, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022... March 29, 2022: The IRS issued a news release reminding...more

Cadwalader, Wickersham & Taft LLP

Revenue Adjusted Lease Payments Are Not REIT Qualifying Income

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On February 4, 2022, the IRS released a private letter ruling revoking its prior approval of certain lease payments as “rents from real property” for purposes of the REIT income tests....more

Keating Muething & Klekamp PLL

Two New Private Letter Rulings Inform Code Section 1202's Qualified Trade or Business Analysis

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Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more

Freeman Law

The Rescission Doctrine: Unwinding a Transaction for Tax Purposes

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What are the tax consequences of unwinding a transaction? And just when, if ever, is a taxpayer entitled to the transactional equivalent of a mulligan—a do-over? The ability to unwind a transaction depends upon the...more

Williams Mullen

[Webinar] Spring Tax Forum 2021 - June 8th, 11:00 am - 12:00 pm EDT

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Please join us for the Spring Tax Forum to be held virtually on Tuesday, June 8, 2021. Register to join Jenny Connors, Philip Delano, Marie Yascko-Rosado and Kevin Bender for an informative discussion on the latest updates in...more

McDermott Will & Emery

Weekly IRS Roundup December 28, 2020 – January 8, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021... December 29, 2020: The IRS released Revenue Procedure...more

McDermott Will & Emery

Weekly IRS Roundup May 4 – May 8, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more

Burr & Forman

South Carolina Sales Tax on Cloud Based Services

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South Carolina imposes sales tax on retail sales of tangible personal property. South Carolina generally does not impose a sales tax on intangible property, however, certain intangible property is deemed to be tangible...more

McDermott Will & Emery

Weekly IRS Roundup November 11 – 15, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11–15, 2019. November 11, 2019: The IRS released Delegation Order 30-9 announcing the...more

McDermott Will & Emery

Weekly IRS Roundup October 21 – 25, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 21 – 25, 2019. October 21, 2019: The IRS issued a news release in which it announced the...more

McDermott Will & Emery

Weekly IRS Roundup June 17 – 21, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17 – 21, 2019. June 18, 2019: The IRS issued a news release noting that it and the US...more

Laner Muchin, Ltd.

IRS No Longer Prohibits Lump Sum Payouts To Retirees In Pay Status

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The IRS previously issued several Private Letter Rulings permitting defined benefit plans to offer lump sum windows during which retirees receiving annuity payments could elect to receive the actuarial equivalent of their...more

McDermott Will & Emery

Weekly IRS Roundup February 11 – 15, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 11 – 15, 2019. February 11, 2019: The IRS issued a news release promoting online...more

Bracewell LLP

Bracewell Tax Report - January 2019

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Holland & Knight LLP

IRS May Allow Employer Contributions to 401(k) Plans for Employees Repaying Student Loans

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• With growing student loan debt pushing employees to delay contributing to their employers' 401(k) plans, many employers have been looking for ways to help their employees save for retirement. • A recent Internal Revenue...more

Mitchell, Williams, Selig, Gates & Woodyard,...

I Missed a Tax Election…Now What? Requesting 9100 Relief

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What do we, as tax professionals, do when we discover (or our clients discover) that a tax election has been inadvertently missed? There may be a solution for some missed elections. Regulations §§ 301.9100-1 through...more

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