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Abstract
In January 2015, Yahoo CEO Marissa Mayer announced the spinoff to shareholders of Yahoo's remaining 384 million shares in Alibaba, now worth $23 billion. But now, the IRS told Yahoo it would not issue a private letter ruling. On these numbers, this is not a little issue. A ruling is an advance blessing from the IRS, a binding letter you attach to your tax return, worth its weight in gold. A tax opinion can be about almost anything. But for rulings, there is a subjective sweet spot. If the tax issue is plain vanilla in character, it may not be possible to get a ruling even if it is not on a no-rule list. Today, almost no ruling is submitted without an informal trial run. You talk to the IRS and get their general view on your proposed ruling. Afterwards, you submit a short memo about the facts, the client, the issue and the ruling you want.