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 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 Corporate Tax