IRS offers Pilot stock distribution Letter Ruling Program

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A new IRS pilot program will allow taxpayers to obtain rulings on tax-free stock distributions. In Revenue Procedure 2017-52, the IRS introduced a pilot program expanding the scope of available letter rulings for an 18-month period to include requests for rulings on the tax consequences of a distribution of stock, or stock and securities, of a controlled corporation under Internal Revenue Code Section 355. The guidance provides procedures to request these rulings and clarifies how to ask for a ruling on significant issues related to these transactions.

Certain IRS fees to be paid electronically

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The IRS announced that beginning June 15, 2017, the Pay.gov electronic payment website will be available for taxpayers to make the required user fee payments when requesting certain IRS rulings. After August 15, Pay.gov will become the only permissible payment method for those fees. Online fees can be paid with Form 1128, Form 2553, Form 3115, Form 8716, Private Letter Rulings and Closing Agreements.

Auto racing team gets a green flag

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When businesses dispose of assets, gain or loss must generally be recognized on tax returns, depending on the nature of the disposition (by sale, exchange, or involuntary conversion). In a private letter ruling, the IRS approved how a Formula 1 auto racing team handled its auto parts disposition for gain and loss purposes. Due to the unique nature of auto racing, the IRS ruled that each part used to build race cars for each specific race was the appropriate asset to be valued for disposition purposes. (PLR 201710006)