IRS Notice 2016-03 confirms that "expiration dates on determination letters issued prior to January 4, 2016 are no longer operative." More on this will be in the forthcoming newsletter and at the NCEO's
On May 10, 2002, the IRS issued Revenue Procedure 2002-38, in which it clarified that under Section 1378 of the Internal Revenue Code, an S corporation's taxable year must normally be its calendar year.
In Private Letter Ruling 200052023, the Internal Revenue Service (IRS) ruled on a merger between two ESOP companies. The target company was owned partly by an ESOP and an individual shareholder; the acquiring company was a 100% ESOP.
In PLR 200052014, the IRS ruled that owners of a company listed on the over-the-counter market can sell to their company ESOP and take Section 1042 rollover treatment on the sale because the over the counter market does not provide sufficient trading volume to make a stock readily tradable.
Within the next few weeks, the IRS will issue a revenue ruling indicating that trustees can vote shares for which ESOP participants do not provide directions.
