SECTION 5. PROCEDURE
Internal Revenue Bulletin 2013-28 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 Rev. Proc. 2013–1 is modified and amplified as follows:
(1) Delete the text of all paragraphs after the first paragraph of section 6.03 and add the following text after the first paragraph of section 6.03:
In addition, the Service will not rule on the qualification of any transaction under section 332, 351, 355, or 1036, or on whether a transaction constitutes a reor
quest a letter ruling on part of a larger transaction or on a particular issue under a Code section that a transaction presented. The Service, in turn, would issue a letter ruling on the particular issue raised in the letter ruling request and not on any other issue (including, in some cases, qualification of the distribution under section 355) or on any other aspect of the transaction.
Prior to the effective date of this revenue procedure, a taxpayer requesting a letter ruling on the qualification of a transaction under section 332, 351, 355, or 1036, or whether a transaction constituted a reorganization within the meaning of section 368, was required to provide information and representations described in other applicable revenue procedures ( i.e., 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; Rev. Proc. 96–30, 1996–1 C.B. 696; and Rev. Proc. 2003–48, 2003–2 C.B. 86, as applicable) as well as other information and representations that were requested as part of the Associate Chief Counsel (Corporate)’s ruling policy.
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