SECTION 18. WHAT IS

THE EFFECTIVE DATE OF THIS REVENUE PROCEDURE?

SECTION 19. PAPERWORK REDUCTION ACT

Director, Employee Plans Examinations Director, Exempt Organizations Examinations Director, Government Entities (Add name of field office handling the request)

Section 5.01 has been amended to clarify that an Associate office will generally issue a letter ruling on a completed transaction as long as the letter ruling request is submitted before a return containing a tax position on the completed transaction is filed, even if a return has been filed for the year in which the transaction took place. Question 5 on the Letter Ruling Checklist in Appendix C has also been amended to reflect this clarification.

Section 9.05(1) has been amended to reflect that a taxpayer submitting a non-automatic Form 3115 on paper may not submit payment with the paper submission. Rather, the taxpayer must first submit the appropriate user fee payment through www.pay.gov and include a copy of the receipt for this payment with the request.

Section 9.22(2) has been amended to reflect that the method of accounting change procedures described in Treas. Reg. 1.448-1 (to an overall accrual method for the taxpayer’s first taxable year it is subject to § 448) are no longer available because that regulation only applies to tax years beginning before January 1, 2018.

Section 12.05 was added to clarify that in tax-exempt matters, Directors issue determination letters in response to applications for recognition of tax exemption under the jurisdiction of the Commissioner, TE/GE as set forth in Rev. Proc. 2023-5.

Section 15.08 has been amended to reflect that foreign entities that wish to submit payment of a user fee from a foreign bank may submit their payment by check instead of by using www.pay. gov.

Editorial and clarifying changes have been made throughout.