SECTION 5. ON WHAT

ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?

Taxpayers may request letter rulings, information letters and closing agreements on issues within the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division under this revenue procedure. The Service issues letter rulings to answer written inquiries of individuals and organizations about their status for tax purposes and the tax effects of their acts or transactions when appropriate in the interest of sound tax administration.

Taxpayers also may request determination letters that relate to Code sections under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. See Rev. Proc. 2015–6, this Bulletin. See also Rev. Proc. 2015–5, this Bulletin, Rev. Proc. 2015–9 and Rev. Proc. 2015–10, next Bulletin.

Note that issues involving exempt organizations and certain issues involving employee plans and government entities fall under the jurisdiction of the Office of the Associate Chief Counsel (Tax Exempt and Government Entities). See section 5.04 below and Rev. Proc. 2015–1, this Bulletin.

Determination letters .01 The procedures for obtaining determination letters involving §§ 401, 403(a), 409, and 4975(e)(7), and the status for exemption of any related trusts or custodial accounts under § 501(a) are contained in Rev. Proc. 2015–6, this Bulletin. The procedures for obtaining determination letters involving the initial qualification for exempt status of organizations described in §§ 501 and 521 are contained in Rev. Proc. 2015–5, this Bulletin, and Rev. Proc. 2015–9, next Bulletin. The procedures for obtaining determination letters involving classification and reclassification of private foundation status are contained in Rev. Proc. 2015–10, next Bulletin.

Master and prototype plans, volume submitter plans, and prototype plans

Employee Plans Compliance Resolution System

.02 The procedures for obtaining opinion letters for master and prototype plans and any related trusts or custodial accounts under §§ 401(a), 403(a) and 501(a) and advisory letters for volume submitter plans are contained in Rev. Proc. 2011–49. The procedures for obtaining opinion letters for prototype trusts, custodial accounts or annuities under § 408(a), (b), (k) or (p) or 408A, are contained in Rev. Proc. 87–50; Rev. Proc. 91–44; Rev. Proc. 92–38; Rev. Proc. 97–29; Rev. Proc. 98–59; Rev. Proc. 2002–10, and Rev. Proc. 2010–48, as modified by Rev. Proc. 2015–8. The procedures for obtaining opinion and advisory letters for prototype plans and volume submitter plans under § 403(b) are contained in Rev. Proc. 2013–22.

.03 The procedures for obtaining compliance statements, etc., for certain failures of plans qualified under § 401(a), § 403(b) plans, SEPs and § 457 plans under the EPCRS are contained in Rev. Proc. 2013–12, as updated.

Chief Counsel .04 The procedures for obtaining letter rulings, closing agreements, and information letters on issues within the jurisdiction of the Chief Counsel are contained in Rev. Proc. 2015–1, this Bulletin, including tax issues involving interpreting or applying the federal tax laws and income tax treaties relating to international transactions.

Sec. 5.04 January 2, 2015 152 Bulletin No. 2015–1

Alcohol, tobacco, and firearms taxes