IRS Announces Changes to Private Letter Request Rulings: Today, the IRS announced that it is reconsidering its views regarding certain issues on which it has provided favorable rulings in the past. Pending the outcome of a study, the IRS will process ruling requests under new guidelines with respect to certain types of transactions, including: (1) worthless stock losses under section 165(g)(3)(B); (2) certain delayed distributions in connection with a section 355 distribution; (3) “drop-spin-liquidate” transactions; and (4) reorganizations that result in transfers of a portion of a subsidiary’s assets to its corporate shareholder. Private letter rulings issued previously on these matters are not affected.

Miscellaneous Guidance:

IR-2017-172 extends the deadline to file certain individual and business tax returns and make certain tax payments until January 31, 2018. Currently, the IRS is providing relief to seven California counties: Butte, Lake, Mendocino, Napa, Nevada, Sonoma, and Yuba. Individuals and businesses in these localities, as well as firefighters and relief workers who live elsewhere, qualify for the extension.

Notice 2017-63 provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates under section 417(e)(3), and the 24-month average segment rates under section 430(h)(2). The notice also provides guidance as to the interest rate on 30-year Treasury securities under section 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under section 431(c)(6)(E)(ii)(I).