Are PORCs on the IRS’ Endangered Species List?

 In Will's blog

Just wondering if anyone has heard anything within the last few weeks about the IRS Notices regarding the status of PORCs as “abusive” tax shelters and the related filing requirements with OTSA.

After digging into the changes made by the PATH Act affecting PORCs, it appears many will no longer be eligible for favorable tax treatment under Section 831(b) notwithstanding the impact – if any – of Notice 2016-66.

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