In May 2026, the IRS reinstated a previously discarded policy that allows taxpayers to request private letter rulings (PLRs) from the IRS, but only for “significant issues” arising in corporate transactions. In the past, the IRS would, when requested, review entire proposed transactions. This could be time consuming and costly. Now, the agency will issue PLRs only on specific legal questions without ruling on the entire transaction. A company, for example, might ask whether asset transfers following a reorganization would jeopardize its deal’s tax-free treatment. PLRs can help business owners make better decisions about transaction planning and structuring. To learn more, contact us.
