SECTION 2. CHANGES

.01 Section 5.01 of this revenue procedure modifies and amplifies section 6.03, section 6.11, Appendix C, and Appendix E of Rev. Proc. 2013–1, 2013–1 I.R.B. 1 (explaining procedures for requesting letter rulings generally), and section 5.02 of this revenue procedure modifies and amplifies sections 3.01(41), 4.02(2), and 4.02(9) of Rev. Proc. 2013–3, 2013–1 I.R.B. 113 (listing areas of the Code under the jurisdiction of the Associate Chief Counsel (Corporate) on which the Service will not issue letter rulings), by modifying the scope of, and procedures for requesting, letter rulings issued by the Service under section 332, 351, 355, 368, or 1036, and certain related Code sections. As explained in section 4.01 of this revenue procedure, the Service will no longer rule on whether a transaction qualifies for nonrecognition treatment under section 332, 351, 355, or 1036, or on whether a transaction constitutes a reorganization within the meaning of section 368. The Service will instead rule only on significant issues (described in section 4.02 of this revenue procedure) under section 332, 351, 355, 368, or 1036. In addition, as explained in section 4.03 of this revenue procedure, the Service will rule only on significant issues under related Code sections that address the tax consequences (such as nonrecognition and basis) that result from the application of section 332, 351, 355, 368, or 1036. Finally, section 5.01 of this revenue procedure discontinues the pilot program announced in Rev. Proc. 2009–25, 2009–24 I.R.B.1088, for letter

rulings on certain issues arising in the context of a section 355 distribution.

.02 Section 5.03 of this revenue procedure modifies the following revenue procedures, which describe some of the information and representations to be submitted with a letter ruling request for rulings on transactions described in section 332, 351, 355, or 368, by providing that such information and representations should be included in letter ruling requests with respect to one or more significant issues under such Code sections only to the extent that they relate to the significant issues: Rev. Proc. 81–60, 1981–2 C.B. 680 (section 368(a)(1)(E)); Rev. Proc. 83–59, 1983–2 C.B. 575 (section 351); Rev. Proc. 86–42, 1986–2 C.B. 722 (section 368(a)(1)(A), (B), (C), (D) (acquisitive reorganizations), and (F)); Rev. Proc. 90–52, 1990–2 C.B. 626 (section 332); and Rev. Proc. 96–30, 1996–1 C.B. 696, amplified and modified by Rev. Proc. 2003–48, 2003–2 C.B. 86 (section 355).

.03 Additionally, section 5.04 of this revenue procedure supersedes section 4.06 of Rev. Proc. 2003–48, 2003–2 C.B. 86 (relating to supplemental letter rulings) and obsoletes all other sections of Rev. Proc. 2003–48 (relating to procedures for requesting letter rulings under section 355).