PART II CIRCLE SECTION›Rev. Proc. 2023-7
SECTION 3. AREAS IN WHICH
Internal Revenue Bulletin 2023-1 · 2026-10-03 edition · updated 2026-10-04 · United States
LETTER RULINGS OR DETERMINATION LETTERS WILL NOT BE ISSUED
.01 Specific Questions and Problems (1) Section 861.—Income from Sources Within the United States.—A method for determining the source of a pension payment to a nonresident alien individual from a trust under a defined benefit plan that is qualified under § 401(a) if the proposed method is inconsistent with §§ 4.01, 4.02, and 4.03 of Rev. Proc. 2004-37, 2004-1 C.B. 1099. (2) Section 862.—Income from Sources Without the United States.—A method for determining the source of a pension payment to a nonresident alien individual from a trust under a defined benefit plan that is qualified under § 401(a) if the proposed method is inconsistent with §§ 4.01, 4.02, and 4.03 of Rev. Proc. 2004-37, 2004-1 C.B. 1099. (3) Section 871(g).—Special Rules for Original Issue Discount.—Whether a debt instrument having original issue discount within the meaning of § 1273 is not an original issue discount obligation within
Bulletin No. 2023–1 305 January 3, 2023
quest for competent authority assistance under a United States income tax treaty.
(6) A “comfort” ruling will not be issued with respect to an issue that is clearly and adequately addressed by statute, regulations, decisions of a court, tax treaties, revenue rulings, or revenue procedures absent extraordinary circumstances (e.g., a request for a ruling required by a governmental regulatory authority in order to effectuate the transaction).
(7) Any frivolous issue, as that term is defined in § 6.10 of Rev. Proc. 2023-1.
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