SECTION 19. WHAT .01 Section 5.01 through 5.04 of Rev. Proc. 98–2 is redesignated as…

SIGNIFICANT CHANGES through 5.01(4) in this revenue procedure. New section 5.02 is added to reflect the special HAVE BEEN MADE TO procedures in Rev. Proc. 98–17, 1998–5 I.R.B. 21, for taxpayer-initiated requests for REV. PROC. 98–2? written guidance on the tax treatment of environmental cleanup costs.

.02 Section 7.02 is amended to provide that a district director may not request technical advice on an issue if an appeals office is currently considering an identical issue of the same taxpayer (or related taxpayer), including the applicability of any of the federal taxes involved when more than one kind of federal tax is dependent on the resolution of that issue.

.03 Section 8.04 is amended to provide that the pre-submission conference generally should be held within 30 calendar days after the district or appeals office is contacted by the branch assigned responsibility for conducting the conference.

.04 Section 9.01(4) is added to require the submission of a copy of the relevant parts of all foreign laws whether the request for technical advice is initiated by the taxpayer or by a district or appeals office. If English is not the official language of the country involved, section 9.01(4) also requires the submission of a copy of an English language version of the foreign laws.

.05 Section 9.01(5) is added to require the submission of a certified English translation of the relevant parts of documents in a language other than English whether the request for technical advice is initiated by the taxpayer or by a district or appeals office. Section 9.01(5) also provides the standards for the acceptability of certified English translations.

.06 Section 10.05 is added to provide that if the interpretation of a foreign law or foreign document is a material fact, the national office, at its discretion, may refuse to provide technical advice.

.07 Section 15.14 is amended to provide that if the transmittal memorandum (Form M6000) provides more than the fact that the the technical advice memorandum is attached or the case is returned for further development, the transmittal memorandum may constitute Chief Counsel Advice subject to disclosure under § 6110.

SECTION 20. WHAT IS THE Rev. Proc. 98–2, 1998–1 I.R.B. 74, as amplified and modified by Rev. Proc. 98–17, EFFECT OF THIS REVENUE 1998–5 I.R.B. 21, is superseded. PROCEDURE ON OTHER DOCUMENTS?

Sec. 20

1999–1 I.R.B. 99 January 4, 1999