IRS offers Pilot stock distribution Letter Ruling Program

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.