SECTION 5. UNDER WHAT p. 17

CIRCUMSTANCES DOES THE NATIONAL OFFICE .01 In income and gift tax matters ISSUE LETTER RULINGS?

.02 A § 301.9100 request for extension of time for making an election or for

other relief .03 Determinations under § 999(d) of the Internal Revenue Code

.04 In matters involving § 367

.05 In estate tax matters

.06 In matters involving additional estate tax under § 2032A(c)

.07 In matters involving qualified domestic trusts under § 2056A

.08 In generation-skipping transfer tax matters

.09 In employment and excise tax matters

.10 In administrative provisions matters

.11 Generally not to business associations or groups

.12 Generally not to foreign governments

.13 Generally not on federal tax consequences of proposed legislation

.14 Issuance of a letter ruling before the issuance of a regulation or other

published guidance