SECTION 2. WHAT

CHANGES HAVE BEEN MADE TO REV. PROC. 2014–4?

This revenue procedure explains how the Internal Revenue Service gives guidance to taxpayers on issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. It explains the kinds of guidance and the manner in which guidance is requested by taxpayers and provided by the Service. A sample format of a request for a letter ruling is provided in Appendix A.

.01 This revenue procedure is a general update of Rev. Proc. 2014–4, 2014–1 I.R.B. 125, which contains the Service’s general procedures for employee plans and exempt organizations letter ruling requests. As a result of the realignment of the Tax Exempt and Government Entities Division (TE/GE), the technical responsibility for issuing technical advice and letter rulings shifted from EO Technical to the Office of Associate Chief Counsel (Tax Exempt and Government Entities). EP Rulings and Agreements will continue to issue letter rulings only on certain matters specified in Rev. Proc. 2015–4. Rev. Proc. 2015–1, this Bulletin, sets forth procedures for obtaining letter rulings from the Office of Associate Chief Counsel, including letter rulings relating to tax-exempt organizations, qualified retirement plans, and IRAs. Rev. Proc. 2015–2, this Bulletin, sets forth procedures for requesting technical advice from the Office of Associate Chief Counsel.

.02 In addition to minor revisions, such as updating citations to other revenue procedures, the following changes have been made:

(1) References to Rev. Proc. 2014–5 have been replaced with references to Rev. Proc. 2015–2 to reflect that technical advice memoranda will be issued by the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(2) Section 3 has been modified to change the headline from “Commissioner” to “Service;”

(3) Section 3.03 has been modified to clarify the definition of a closing agreement;

(4) Section 3.04 has been modified to clarify which offices may issue determination letters for exempt organizations;

(5) Section 3.06 has been modified to state that EO will no longer issue information letters;

(6) Section 3.09 has been modified to update the address for Nonbank trustee requests;

(7) Section 4 has been modified to include references to Rev. Procs. 2015–1, 2015–5, 2015–9, and 2015–10;

(8) Section 5.01 has been modified to include cross references for requests for determination letters for exempt organizations;

Sec. 2.02 Bulletin No. 2015–1 147 January 2, 2015

(9) Section 5.03 has been deleted due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(10) Section 6.01 has been modified to reflect the subject matters that EP Rulings and Agreements will issue rulings on due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(11) Section 6.02 has been modified to state that Exempt Organizations no longer issues letter rulings;

(12) Section 6.03 has been modified to clarify the subject matters that are subject to a determination letter that is issued by Employee Plans;

(13) Section 6.04 has been modified to remove the reference to applications for recognition of exemption;

(14) Sections 6.05 to 6.09 have been modified to reflect that Exempt Organizations will no longer issue letter rulings due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(15) Section 6.10 to 6.18 have been deleted due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(16) Sections 7.05 and 7.08 have been modified by changing EP or EO Technical to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(17) Sections 8.08, 8.11 through 8.17 have been deleted to reflect the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(18) Sections 9.02(5)(c) and (d) have been modified by the addition of the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(19) Section 9.02(10) has been modified to refer to Form 1023–EZ;

(20) Section 9.03(3) has been modified to state that certain EO Determination Letter requests are not eligible for expedited handling;

(21) Section 9.04 has been modified to change the mailing addresses and to delete the addresses for EO letter ruling requests;

(22) Section 9.05 has been modified to expand the circumstances under which a taxpayer must notify the Service about the examination of an issue in prior year’s return;

(23) Sections 9.05 to 9.10 have been modified to delete references to EO Technical and EO Examination;

(24) Section 10.02 has been modified by adding a reference to Rev. Proc. 2014–11;

(25) Section 10.03 has been modified by deleting references to Rev. Procs. 94–42, 2004–15; 79–62, and 2011–44 due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(26) Section 11.03 has been modified by deleting the reference to EO Technical;

(27) Section 13.03 has been modified to reflect that the Office of Associate Chief Counsel will handle a request for technical advice pursuant to Rev. Proc. 2015–2;

(28) Sections 13.04 to 13.10 have been modified to clarify the procedures for revoking or modifying a letter ruling, and to further provide that a request for relief under § 7805(b) are

Sec. 2.02 January 2, 2015 148 Bulletin No. 2015–1

under the jurisdiction of the Office of Associate Chief Counsel (Tax Exempt and Government Entities);

(29) Sections 14.01 and 14.02 have been modified to clarify the procedures for revoking or modifying a determination letter, and to further provide that a request for technical advice and a request for relief under § 7805(b) are under the jurisdiction of the Office of Associate Chief Counsel;

(30) Sections 15.01 to 15.03 have been modified by deleting the references to EO Determinations and EO Technical;

(31) Appendix A has been modified by updating the mailing address; and

(32) Appendices D and E have been deleted due to the transfer of technical work from TE/GE to the Office of Associate Chief Counsel (Tax Exempt and Government Entities).