Overview
IRS Announces Letter Ruling Program for Tax-Free Stock Distributions: Today, the IRS issued Revenue Procedure 2017-52 announcing an 18-month pilot program under which it will accept letter ruling requests on the tax consequences of transactions intended to qualify as tax-free stock distributions. This ruling modifies Revenue Procedure 2013-32 in which the IRS stated that it would no longer rule on the tax consequences of distributions intended to qualify for tax-free treatment under section 355.
European Commission Calls for Fair Taxation of Digital Economy: Today, following on the EU Council of Economy and Finance Ministers’ (ECOFIN) Sept. 16 agreement, the European Commission launched a new EU agenda to ensure income earned from the provision of digital goods and services in the EU is taxed fairly and in line with the taxation faced by brick and mortar businesses. The commission stated it continues to believe that its proposal for a common consolidated corporate tax base is the best solution for this problem. Today’s communication paves the way for a legislative proposal for EU rules that could be developed as early as spring 2018.