IRS expands fast track for some corporate letter rulings. (TAX CLINICPROCEDURE & ADMINISTRATION)

Date01 January 2024
AuthorCountryman, Marc,Fattman, Steve,Countryman, Marc^Fattman, Steve

January 1, 2024

The IRS has established in Rev. Proc. 2023-26 a permanent program for fast-tracking corporate letter rulings that meet certain guidelines. This program replaces the pilot program under Rev. Proc. 2022-10, with two notable changes, and applies to ruling requests received by the IRS after July 26, 2023.

Background

In January 2022, the IRS announced that it was conducting an 18-month pilot program allowing taxpayers to request fast-track processing of corporate letter rulings if they met the guidelines in Rev. Proc. 2022-10. The IRS said it would strive to issue a ruling within 12 weeks after the request.

Notable changes

The permanent program formalizes the pilot program...

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