SECTION 1. PURPOSE AND NATURE

OF CHANGES

.01 The purpose of this revenue procedure is to update Rev. Proc. 98–7, 1998–1 C.B. *, by providing a current list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (International) on which the Internal Revenue Service will not issue advance letter rulings or determination letters. For a list of areas under the jurisdiction of the Associate Chief Counsel (Domestic) and the Associate Chief Counsel (Employee Benefits and Exempt Organization) relating to issues on which the Service will not issue letter rulings or determination letters, see Rev. Proc. 99–3, this Bulletin.

.02 Changes (1) Section 4.02(2) is amended to clarify that the Service will not normally rule on transactions that are designed to achieve a different tax consequence or classification under U.S. tax law and the tax law of a foreign country, where the results of that different tax consequence or classification are inconsistent with the purposes of U.S. tax law.

(2) New paragraphs 4.02(5)(a) and (b) dealing with the interpretation of foreign law and foreign documents have been added to reflect the fact that the Service ordinarily does not rule on situations in

volving the interpretation of foreign law or foreign documents. The interpretation of a foreign law or foreign document means making a judgment about the import or effect of the foreign law or document that goes beyond its plain meaning. The Service, at its discretion, may consider rulings that involve the interpretation of foreign laws or foreign documents.