Rev. Proc. 2017-XX (1)introduces a
pilot program expanding the scope of letter rulings available from
the Internal Revenue Service (Service) to include rulings on the
tax consequences of a distribution of stock and securities of a
controlled corporation under § 355 for a specified period of time
(see section 6 of this revenue procedure), (2) provides procedures
for taxpayers requesting these rulings, and (3) clarifies
procedures for taxpayers requesting rulings on significant issues
relating to these transactions. These Revenue Procedures explain
how the Service provides advice to taxpayers on issues under the
jurisdiction of the Associate Chief Counsel (Corporate), the
Associate Chief Counsel (Financial Institutions and Products), the
Associate Chief Counsel (Income Tax and Accounting), the Associate
Chief Counsel (International), the Associate Chief Counsel
(Passthroughs and Special Industries), the Associate Chief Counsel
(Procedure and Administration), and the Associate Chief Counsel
(Tax Exempt and Government Entities). It explains the forms of
advice and the manner in which advice is requested by taxpayers and
provided by the Service. This information is required to evaluate
and process the request for a letter ruling or determination
letter.
The IRS released Revenue
Procedure 2017-52 to the public on Sept 21, 2017, which (1)
introduces a pilot program expanding the scope of letter rulings
available from the Internal Revenue Service (Service) to include
for a period of time (see section 6 of this revenue procedure)
rulings on the tax consequences of a distribution of stock, or
stock and securities, of a controlled corporation under § 355 of
the Internal Revenue Code (Code), (2) provides procedures for
taxpayers requesting these rulings, and (3) clarifies procedures
for taxpayers requesting rulings on significant issues relating to
these transactions. Since this Revenue Procedure could not be
released for public comment previously and has immediate effect, it
is being submitted for review using emergency clearance procedures.
OMB action is requested by 9/29/2017 so that taxpayers will be able
to take advantage of the expanded availability of private letter
rulings as soon as possible.
US Code:
26
USC 7805 Name of Law: Rules and Regulations
Revenue Procedure 2017-52
modifies and amplifies Revenue Procedures 2017-1 and 2017-3. No
current information collection requirements will be
removed/deleted. Section 3 of 2017-52 will add new information
collection requirements to 2017-1 and 2017-3. Section 4 of 2017-52
will update the current information collection requirements found
in 2017-1 and 2017-3. These changes to 2017-01 and 2017-03 will
increase the estimated average burden per respondent to 81 hours,
resulting in an addition of 4,416 hours of burden across all
respondents. 2017-52 is also expected tin increase the estimated
number of respondents and/or record-keepers to 3,986 [increase of
30 from current number of 3,956]. This increase in respondents will
add a further 6,000 hours of burden. Overall, the estimated total
annual reporting and/or recordkeeping burden will be 322,480 hours
[increase of 10,416 hours from current number of 316,020].
$0
No
No
No
No
No
No
Uncollected
Laura Bates 202
317-5418
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.