Rev. Proc. 2011-44 — Internal Revenue Bulletin 2023-1

relating to church plans under section 414(e). Rev. Proc. 2011-44 provides that plan participants and other interested persons must receive a notice when a letter ruling is requested and a copy of the notice must be submitted as part of the ruling request. Rev. Proc. 2011-44 also provides procedures for the Service to receive and consider comments about the ruling request from interested persons. See Appendix E of this revenue procedure.

Rev. Proc. 93-41, 1993-2 C.B. 536, sets forth procedures relating to the issuance of an administrative scrutiny determination, which is a determination by the Service as to whether a separate line of business satisfies the requirement of administrative scrutiny, within the meaning of § 1.414(r)6, for the testing year.

Bulletin No. 2023–1 101 January 3, 2023

461(h) Alternative method for the inclusion of common improvement costs in basis

482 Advance pricing agreements

521 Appeal procedure with regard to adverse determination letters and revocation or modification of exemption letter rulings and determination letters

817(h) Closing agreement for inadvertent failures of variable contracts

860 Self Determination of Deficiency Dividend

877, 2107, and 2501(a)(3) Individuals who lose U.S. citizenship or cease to be taxed as long-term U.S. residents with a principal purpose to avoid U.S. taxes

1059(c)(4) Fair market value of stock for purposes of election

1362(b)(5) and 1362(f) Relief for late S corporation and related elections under certain circumstances

1362(b)(5) and 301.7701-3 Automatic extensions of time for late S corporation election and late corporate entity classification

1.1502-13(e)(3) Consent to treat intercompany transactions on a separate entity basis and revocation of this consent

1.1502-75(b) Consent to Be Included in a Consolidated Income Tax Return