SECTION 3. SCOPE

.01 Automatic Permission . This revenue procedure provides automatic permission to Qualified Master-Feeder Structures (QMFSs), as described in section 4 of this revenue procedure, to aggregate built-in gains and losses from contributed securities for purposes of making § 704(c) and reverse § 704(c) allocations. The Service will no longer issue letter rulings to QMFSs allowing this type of aggregation. But see section 6.02 of this revenue procedure.

.02 Securities Partnerships That Do Not Qualify for Automatic Permission . The Service recognizes that there may be securities partnerships not described in section 4 of this revenue procedure that should be allowed to aggregate built-in gains and losses from contributed property where the burden of making § 704(c) allocations is great and the likelihood of character and timing distortions is minimal. Therefore, the Service will continue to consider ruling requests from these partnerships. Section 5 of this revenue procedure describes the information to be submitted in such a ruling request.