SECTION 1. PURPOSE AND

NATURE OF CHANGES

.01 Purpose This revenue procedure updates Rev. Proc. 95–7, 1995–1 C.B. 482 by providing a list of subject matters under the jurisdiction of the Associate Chief Counsel (International) in which the Internal Revenue Service will not issue advance letter rulings or determination letters. Rev. Proc. 96–3, page 82, this Bulletin, lists the subject matters under the jurisdiction of the Associate Chief Counsel (Domestic) in which the Service will not issue advance letter rulings or determination letters.

.02 Changes New section 4.01.25, dealing with various issues that arise in determining whether an intermediate entity is a conduit entity for purposes of sections 881, 882, 1441 or 1442, has been added to reflect the Service’s view that the stated issues require fact and circumstance determinations that are not the proper subject of advance letter rulings and determination letters.