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 uncertain as to whether an Associate has jurisdiction with regard to a specific factual situation may call the telephone number for the Associate office listed in section 10.07(1) of this revenue procedure.

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 7.03(2) of this revenue procedure for the address to which to send 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

Sec. 2.04 January 7, 2008 8 2008–1 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)