SECTION 1. PURPOSE AND

NATURE OF CHANGES

.01 The purpose of this revenue procedure is to update Rev. Proc. 2005–3, 2005–1 C.B. 118, by providing a revised list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue Service will not issue letter rulings or determination letters. For a list of areas under the jurisdiction of the Associate Chief Counsel (International) relating to international issues on which the Service will not issue letter rulings or determination letters, see Rev. Proc. 2006–7, this Bulletin. For a list of areas under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division relating to issues, plans or plan amendments on which the Service will not issue letter rulings and determination letters, see, respectively, section 8 of Rev. Proc. 2006–4 (this Bulletin) and section 3.02 of Rev. Proc. 2006–6 (this Bulletin).

.02 Changes.

(1) New section 3.01(3) (Sections 61, 451, and 1001.—Gross Income Defined...) has been added. See Rev. Proc. 2005–61, 2005–37 I.R.B. 507.

(2) Section 3.01(9) (Section 105(h). —Amount Paid to Highly Compensated Individuals Under Discriminatory Self-Insured Medical Expense Reimbursement Plan) has been modified to simplify the language.

(3) New section 3.01(11) (Section 107.—Rental Value of Parsonages) has been added.

(4) Section 3.01(33) (Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of

Subsidiaries...) has been modified regarding the definition of “Significant Issue.” See Rev. Proc. 2005–68, 2005–41 I.R.B. 694.

(5) Section 4.01(30) (Section 441(i).—Taxable Year of Personal Service Corporations) has been modified to update the regulation citation.

(6) Section 4.01(37) (Section 664.—Charitable Remainder Trusts) has been modified to indicate that this no-rule area includes unitrust payments for a term of years.

(7) Section 4.01(44) (Section 2055.—Transfers for Public, Charitable, and Religious Uses) has been modified to include annuity or unitrust payments for a term of years.

(8) Section 4.01(48) (Section 2522.—Charitable and Similar Gifts) has been modified to include annuity or unitrust payments for a term of years.

(9) New section 5.02 (Sections 101 and 7702.—Certain Death Benefits; Life Insurance Contract Defined) has been added.

(10) Section 5.03 (Section 409A.—Inclusion in Gross Income of Deferred Compensation Under Nonqualified Deferred Compensation Plans) has been modified by including in this no-rule area the question of whether an arrangement is an arrangement described in § 409A.