Publications Memos Go Back Recent Proposed Regulations Defining the Scope of a Plan Under Section 355(e) 02.01.01 The Internal Revenue Service issued new proposed regulations defining the scope of a plan under section 355(e). Related Insights 01.20.26 | Publications Fifth Circuit Rules That Soroban Was Incorrectly Decided and SECA Tax Exception Applies to Limited Partners With Limited Liability Regardless of Activities 12.15.25 | Publications IRS Releases Final and Proposed Regulations Under Section 892 10.21.25 | Publications IRS Releases Proposed Regulations Under Section 897 on Domestically Controlled REITs Related Services Related Practice Areas Tax