SECTION 1. PURPOSE AND — Internal Revenue Bulletin 2007-1

NATURE OF CHANGES

.01 The purpose of this revenue procedure is to update Rev. Proc. 2006–3, 2006–1 C.B. 122, 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. 2007–7, 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. 2007–4 (this Bulletin) and section 3.02 of Rev. Proc. 2007–6 (this Bulletin).

.02 Changes.

(1) New section 3.01(58) (Section 2601.—Tax Imposed. Exceptions: Retention of Trust’s Generation-Skipping Transfer Tax Exempt Status in the Case of Modifications, Etc.) has been added.

(2) New section 3.01(65) (Section 7704.—Certain Publicly Traded Partnerships Treated as Corporations) has been added.

(3) New section 5.03 (Sections 162 and 1502.—Trade or Business Expenses; Consolidated Returns) has been added.

(4) New section 5.04 (Sections 302 and 304.—Certain Redemptions) has been added.

(5) New section 5.05 (Sections 351, 358 and 362(a).—Transfers to Corporation Controlled by Transferors; Basis to Distributees; Basis to Corporations) has been added.

(6) Old Section 5.10 (Sections 3121, 3306, and 3401.—Definitions; Employment Taxes) has been deleted.

(7) Section 6.07 (Sections 1502, 1504, and 1552.—Regulations; Definitions; Earnings and Profits) updated with cites to Rev. Proc. 2006–21, 2006–24 I.R.B. 1050.