SECTION 3. BACKGROUND

.01 Letter Rulings, In General Ordinarily, the Service will not issue a letter ruling on only part of an integrated transaction. If, however, part of an integrated transaction falls under an area of the Code, including those under the jurisdiction of the Associate Chief Counsel (Corporate), on which the Service will not issue letter rulings (“no-rule issue” or “no-rule area”), the Service may issue a letter ruling on other parts of the transaction. Section 6.03 of Rev. Proc. 2013–1, 2013–1 I.R.B. 15, and section 4.02(2) of Rev. Proc. 2013–3, 2013–1 I.R.B. 122. If it is impossible for the Service to determine the tax consequences of a larger transaction without resolving a no-rule issue then the taxpayer must state in its ruling request to its best knowledge and belief the tax consequences of the no-rule issue. The Service’s letter ruling will state

2013–28 I.R.B. 55 July 8, 2013

by this revenue procedure, as well as Rev. Proc. 2013–1, in general. All pertinent no-rule policies described in Rev. Proc. 2013–3, 2013–1 I.R.B. 113, governing the Service’s letter ruling practice will govern requests for letter rulings made pursuant to this revenue procedure. See, for example, section 3.01(43) of Rev. Proc. 2013–3, 2013–1 I.R.B. 116 (no-rule policy regarding business purpose and device issues under section 355 and section 355(e) plan issues).

In preparing a letter ruling request under this revenue procedure, taxpayers should continue to consult other applicable revenue procedures ( e.g., Rev. Proc. 81–60, 1981–2 C.B. 680; Rev. Proc. 83–59, 1983–2 C.B. 575; Rev. Proc. 86–42, 1986–2 C.B. 722; Rev. Proc. 90–52, 1990–2 C.B. 626; and Rev. Proc. 96–30, 1996–1 C.B. 696) and include in the letter ruling request the information and representations described in such revenue procedures (as appropriate) only to the extent that they relate to the significant issues.

.02 Supplemental Letter Rulings The Associate Chief Counsel (Corporate) will apply the same no-rule policy described above to supplemental letter ruling requests. A change of circumstances arising after a transaction has been completed ordinarily will not present a significant issue with respect to the transaction. In addition, an issue of fact (as opposed to an issue of law) does not present a significant issue. Before submitting a supplemental letter ruling request, a taxpayer is encouraged to call the Office of Associate Chief Counsel (Corporate) at (202) 622–7700 to discuss whether the Service will entertain a supplemental letter ruling request. All pertinent no-rule policies governing the Service’s letter ruling practice will govern requests for supplemental letter rulings.