The IRS has started a new program that allows corporate taxpayers to request official guidance on complex tax questions about transactions, according to Accounting Today. 

Revenue Procedure 2026-21, released last week, creates the program for issues managed only by the IRS Office of Associate Chief Counsel (Corporate). It addresses key legal questions about how transactions are taxed or classified under sections such as 332, 351, 355, 368, and 1036 of the Internal Revenue Code. 

The IRS explained that this program is meant for unresolved and important legal questions, not just to reassure taxpayers. The guidance states that a significant issue must be a “germane and specific issue of law,” rather than a “comfort ruling” where “the conclusion in such a ruling otherwise would not be essentially free from doubt.” 

Taxpayers who want a ruling must submit detailed documentation. This includes a full description of the transaction, a clear statement of the legal issue, and an explanation of why current rules do not fully answer the question. They also need to specify the exact ruling they want and confirm that all issues fall within the associate chief counsel’s area.