Publications Memos Go Back IRS Liberalizes Regulations Defining the Scope of a Plan Under section 355(e) 05.06.02 This memorandum addresses new temporary and proposed IRS regulations that define the scope of a plan under section 355(e) of the Internal Revenue Code. Related Insights 08.05.26 | Publications IRS Notice 2026-36 on Section 4960 08.05.26 | Publications Debt-For-Equity Exchanges Developments – New FINRA Rule 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 Related Services Related Practice Areas Corporate Tax