SECTION 1. PURPOSE AND NATURE

OF CHANGES

.01 This revenue procedure updates Rev. Proc. 2007–7, 2007–1 C.B. 227, by providing a current list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (International) relating to matters on which the Internal Revenue Service will not issue letter rulings or determination letters.

.02 Changes (1) Section 3.01(6) (Section 1503(d)–Dual Consolidated Loss), dealing with whether the conditions under the regulations for excepting a net operating loss of a dual resident corporation from the definition of a dual consolidated loss, or for rebutting the presumption that an event constitutes a triggering event for purposes of § 1.1503–2(g)(2)(iii)(B) are satisfied, is deleted.

(2) Section 4.01(25) (Section 1503(d)–Dual Consolidated Loss), is modified to include the following issues: whether foreign income tax laws deny any opportunity for the foreign use of a dual consolidated loss under § 1.1503(d)–3(e)(1); whether no possibility of foreign use exists under § 1.1503(d)–6(c)(1); whether an event presumptively constitutes a triggering event under § 1.1503(d)–6(e)(1)(i)–(ix); whether the presumption of a triggering event is rebutted under § 1.1503(d)–6(e)(2); and whether a domestic use agreement terminates under § 1.1503(d)–6(j)(1). The modification also provides that the Service will not ordinarily rule on the corresponding provisions of prior regulations under section 1503(d). Finally, the determination whether an event presumptively constitutes a triggering event for purposes of § 1.1503–2(g)(2)(iii)(A)(1)–(7) is deleted.