N-2024-38 & RP-2024-24: Private letter rulings for Section 355 transactions

Revenue Procedure 2024-24 provides updated procedures for taxpayers requesting private letter rulings from the IRS regarding certain matters pertaining to section 355 transactions, including representations, information, and analysis to be submitted with those requests. This revenue procedure modifies Rev. Proc. 2017-52, 2017-41 I.R.B. 283, and supersedes Rev. Proc. 2018-53, 2018-43 I.R.B. 667.?

Notice 2024-38 accompanies Rev. Proc. 2024-24, which provides procedures for requesting private letter rulings from the IRS regarding certain matters pertaining to section 355 transactions. Specifically, this notice requests public feedback on the provisions set forth in the Rev. Proc. 2024-24 and describes the Treasury Department?s and the IRS?s views and concerns relating to certain matters addressed in the revenue procedure.?

Revenue Procedure 2024-24 and Notice 2024-38 will be published in Internal Revenue Bulletin 2024-21 on May 20, 2024.

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