SECTION 4. PROCEDURE

Pursuant to its authority under section 301.7701(i)–4(a)(3), the Internal Revenue Service will not assert that any Fund (or portion thereof) or entity (or portion thereof) to which this Revenue Procedure applies constitutes a TMP for purposes of section 7701(i). Thus, for example, the Internal Revenue Service will not assert that the portion of a RIC or REIT which consists of equity interests in a Fund described in section 3.01 constitutes

a TMP for purposes of section 7701(i). In addition, the debt issued by a Fund (or entity wholly-owned by a Fund) will be disregarded in determining whether an entity referenced in section 3.03 (or portion thereof) is a TMP for purposes of section 7701(i).