IRS Will Restart ‘Significant-Issue’ Letter Rulings on Spin-Offs

The IRS will resume providing private letter rulings to taxpayers on “significant issues” within their corporate reorganizations and spinoffs under certain circumstances, the agency said Tuesday.

Under the new program, taxpayers will be able to request significant-issue rulings on spin-offs and reorganizations if they involve matters that are solely under the jurisdiction of the agency’s Associate Chief Counsel (Corporate), the IRS said in a revenue procedure (Rev. Proc. 2026-21). The issues involved must be “germane and specific,” the IRS said.

Significant-issue rulings deal with a specific aspect of a transaction rather than requiring that a ruling be about ...