SECTION 6. SCOPE AND EFFECT

OF REVENUE PROCEDURE

.01 Exclusivity .

The safe harbor set forth in section 5 of this revenue procedure is available solely for purposes of determining whether the COI requirement is satisfied. Further, the safe harbor may be applied only to transactions that satisfy the requirements of section 3 of this revenue procedure and only to determine the value of Exchange Traded Stock under a Safe Harbor Valuation Method described in section 4.01 of this revenue procedure using the appropriate Measuring Period described in section 4.02 of this revenue procedure. No inference should be drawn regarding the application of any federal tax principles outside the scope of this revenue procedure.

.02 Effect of Safe Harbor Not Applying .

If the safe harbor does not apply, this revenue procedure has no effect on the federal tax treatment of the transaction. In such cases, the determination of whether a transaction satisfies the COI requirement will be made under general federal tax principles without regard to the provisions of this revenue procedure.

.03 Private Letter Rulings .

Subject to the provisions of Rev. Proc. 2018–1, 2018–1 I.R.B. 1, and Rev. Proc. 2018–3, 2018–1 I.R.B. 130, the IRS will entertain requests for rulings and determi

nation letters regarding transactions and legal issues to which the safe harbor does not apply and regarding the applicability of the safe harbor.