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No more ‘comfort’ in IRS private rulings

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in Small Business Tax

Budget cuts at the IRS are being felt in several places. In addition to closing its doors for several extra days this summer, the agency has announced it is cutting back on private letter rulings. (IRS Revenue Procedure 2013-32)

To conserve its resources, the IRS is limiting the scope of rulings to corporate transactions like tax-free reorganizations, corporate formations and liquidations and spin-offs. Thus, it will no longer issue “comfort” rulings on issues where the outcome is settled, but it will continue to rule privately on major issues where the tax law isn’t clear.

The changes apply to private letter ruling requests postmarked after Aug. 23, 2013.

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