Rev. Proc. 2003-33, 2003-1 C.B. 803, provides guidance as to how an automatic extension…

under § 301.9100-3 of the Treasury Regulations may be obtained to file elections under § 338. Rev. Proc. 2003-33 also informs taxpayers who do not qualify for the automatic extension of the information necessary to obtain a letter ruling.

See section 3.01 of Rev. Proc. 2023-3, this Bulletin, which states that the Service will not issue a letter ruling on whether certain transfers to controlled corporations qualify for nonrecognition treatment under § 351. However, the Service will issue a letter ruling addressing significant issues (within the meaning of section 3.01 of Rev. Proc. 2023-3) presented in a transaction described in § 351. The information and representations described in Rev. Proc. 83-59, 1983-2 C.B. 575, should be included in a letter ruling request only to the extent that they relate to the significant issues with respect to which the letter ruling is requested. See section 6.03(3) of this revenue procedure.