On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more
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
On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more
9/30/2019
/ Acquisitions ,
Built-In Gains ,
Change in Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Section 382 ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury