IRS Cautions on Scope of ‘Significant-Issue’ Ruling Program

The IRS may be ready to resume issuing private letter rulings on “significant issues” within corporate transactions, but the scope of the program won’t be unlimited, an IRS official said Thursday.

The agency isn’t looking “to go super-deep” on every potential issue that companies might raise about their transactions, said Robert Liquerman, special counsel in the IRS Office of Associate Chief Counsel (Corporate).

But “we do want to have that flexibility if we see something in there that’s an obvious concern for us,” said Liquerman, who was speaking at a Texas Federal Tax Institute conference in San Antonio.

The ...