IRS Establishes a Significant Issue Ruling Program for Certain Transactions

The U.S. IRS has issued Revenue Procedure 2026-21, which establishes a significant issue ruling program to allow taxpayers to request rulings on one or more issues that (1) are solely under the jurisdiction of the Associate Chief Counsel (Corporate), (2) are significant, and (3) involve the tax consequences or characterization of a transaction (or part of a transaction). This covers transactions described in Internal Revenue Code (IRC) sections:

• 332 - Complete liquidations of subsidiaries
• 3…