06 May 2026

IRS reinstates program for significant issue letter rulings for certain merger and acquisition transactions

The IRS on May 5, 2026, in Revenue Procedure 2026-21, the IRS reinstated a program allowing the Associate Chief Counsel (Corporate) to issues letter rulings on significant issues concerning the tax consequences or characterization of certain corporate transactions described in IRC Sections 332, 351, 355, 368 or 1036 without having to rule on the entire transaction. A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2026-1001