IRS establishes program for rulings on significant issues

The IRS recently issued guidance (Rev. Proc. 2026-21) on the establishment of a program for rulings on significant issues to allow taxpayers to request rulings on one or more issues that:

• Are solely under the jurisdiction of the Associate Chief Counsel (Corporate);
• Are significant, meaning the issue is a germane and specific issue of law, provided that a ruling on the issue would not be a comfort ruling or the conclusion in such a ruling otherwise would not be essentially free from doubt; and
• Involve the tax consequences or characterization of a transaction (or part of a transaction) that is described in Sec. 332, 351, 355, 368, or 1036.

The IRS said that the program’s purpose is to use its resources more efficiently and to increase the availability and timeliness of letter rulings. Read more.