SECTION 1. PURPOSE

.01 Purpose This revenue procedure updates Rev. Proc. 2022-7, 2022-1 I.R.B. 297, by providing a current list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (International) (hereinafter “the Office”) relating to matters on which the Internal Revenue Service will not issue letter rulings or determination letters.

.02 Changes Section 4.01(1) adds whether a transferee foreign corporation, or any qualified subsidiary or any qualified partnership, is engaged in an active trade or business, under §1.367(a)-3(c)(3)(i)(A), outside of the United States to the list of areas for which letter rulings and determination letters ordinarily will not be issued.