SECTION 1. PURPOSE AND — Internal Revenue Bulletin 2011-1

NATURE OF CHANGES

.01 The purpose of this revenue procedure is to update Rev. Proc. 2010–3, 2010–1 C.B. 110, 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. 2011–7, 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. 2011–4, this Bulletin, and

section 3.02 of Rev. Proc. 2011–6, this Bulletin.

.02 Changes. (1) Section 3.01(48), regarding §§ 451 and 45 and Nonqualified Deferred Compensation Plans of State and Local Governments and Tax-Exempt Organizations, has been modified.

(2) Section 3.01(60), regarding §1033 involuntary Conversions, has been modified.

(3) New section 4.01(45), regarding § 1362(d)(3), has been added.

(4) Section 4.07(53), regarding § 2601and the generation-skipping transfer tax, has been modified.

(5) Old section 5.02, regarding § 72 and “partial annuitization,” has been deleted.

(6) New section 5.09, regarding §§ 661 and 662 and “decanting,” has been added.

(7) New section 5.16, regarding § 2501 and “decanting,” has been added.

(8) New section 5.17, regarding §§ 2601 and 2663 and “decanting,” has been added.

(9) Section 6.02, regarding § 442, has been modified.