SECTION 3. ON WHAT ISSUES

MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE?

Issues under the jurisdiction of the Associate Chief Counsel (Corporate)

Issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products)

Taxpayers may request letter rulings, information letters, and closing agreements under this revenue procedure on issues within the jurisdiction of the Associate offices.

Taxpayers also may request determination letters from the Director in the appropriate operating division on subjects that relate to the Code sections under the jurisdiction of the respective Associate offices. See section 12.08 of this revenue procedure for information on where to send the requests for determination letters.

.01 Issues under the jurisdiction of the Associate Chief Counsel (Corporate) include those that involve consolidated returns, corporate acquisitions, reorganizations, liquidations, redemptions, spinoffs, transfers to controlled corporations, distributions to shareholders, corporate bankruptcies, the effect of certain ownership changes on net operating loss carryovers and other tax attributes, debt vs. equity determinations, allocation of income and deductions among taxpayers, acquisitions made to evade or avoid income tax, and certain earnings and profits questions.

.02 Issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products) include those that involve income taxes and accounting method changes of banks, savings and loan associations, real estate investment trusts (REITs), regulated investment companies (RICs), real estate mortgage investment conduits (REMICs), insurance companies and products, and financial products.

Sec. 2.04 January 3, 2006 8 2006–1 I.R.B.

Issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting)

Issues under the jurisdiction of the Associate Chief Counsel (International)

Issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries)

Issues under the jurisdiction of the Associate Chief Counsel (Procedure and Administration)

Issues under the jurisdiction of the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities)