William Burhop, senior technician reviewer, branch five, in the Internal Revenue Service's Office of Associate Chief Counsel (Corporate), said during the American Bar Association's Virtual Tax Meeting a study project is underway to think about revisions to the transaction rules in Treasury Regulations § 1.1502-13.
That project isn't on the current priority guidance plan. Burhop said drafting teams continue their work on guidance plan projects despite a freeze the Biden administration put in place on new regulations just after President Joe Biden was sworn in.
--Additional reporting by Jon Hill. Editing by Vincent Sherry.
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