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.