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More Changes to IRS Appeals’ Practices?

We have previously commented on changes at the Internal Revenue Service (IRS) Appeals Division, including: (1) the allowance of Appeals to invite representatives from the IRS Examination Division (Exam) and IRS Office of Chief Counsel to the Appeals conference, (2) the limitations on in-person conferences, and (3) the use of “virtual” conferences. IRS Extends Permanent Invitation to Exam to Attend Appeals Conferences Appeals Large Case Pilot Program Draws Criticism Virtual IRS Appeals – A New Frontier? More Changes to IRS Appeals, in Response to Taxpayer and Practitioner Concerns IRS Appeals Chief Donna Hansberry discussed these changes at a recent tax law conference held by the Federal Bar Association. According to reports, Ms. Hansberry wants feedback from practitioners on the compliance attendance and virtual conferences. Regarding compliance attendance at Appeals conferences, Ms. Hansberry indicated that the IRS is still evaluating this pilot program, and...

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IRS Expands Section 355 Ruling Practice

On September 21, the Internal Revenue Service (IRS) released Revenue Procedure 2017-52 which introduces an 18 month pilot program expanding the scope of the IRS’s ruling practice with respect to distributions under Internal Revenue Code (Code) Section 355. Prior to Revenue Procedure 2017-52, the IRS had determined that it would not issue letter rulings on whether a distribution qualified for tax-free treatment under Code Section 355. See Revenue Procedure 2013-32. Instead, the IRS had limited its rulings under Code Section 355 to merely addressing “significant issues.” Id. Now, with the introduction of Revenue Procedure 2017-52, a taxpayer may obtain a “transactional ruling” that specifically addresses the general federal income tax consequences of a transaction intended to qualify as tax-free under Section 355. Practice Point: A letter ruling is an excellent way for taxpayers to gain certainty with respect to a Section 355 transaction and to head off...

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