As the Internal Revenue Service (IRS) “no ruling” policy continues to expand, the question our clients are now routinely facing is what to do to achieve that same upfront certainty with respect to the outcome of transactions, restructurings, and tax planning in the absence of a ruling. This issue is particularly relevant in the retirement and benefits field where the IRS has instituted a “no rulings” policy on a number of important issues. As an alternative, tax insurance is an effective tool that can provide certainty should a plan be out of compliance or in the event of unintended tax consequences.
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