SECTION 1. PURPOSE AND

NATURE OF CHANGES

.01 Purpose. The purpose of this revenue procedure is to update Rev. Proc. 2024-3, 2024-1 I.R.B. 143, by providing a revised list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs, Trusts and Estates), the Associate Chief Counsel (Energy, Credits, and Excise Tax), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) (EEE) relating to issues on which the Internal Revenue Service (the “Service”) will not issue letter rulings or determination letters. For a list of areas under the jurisdiction of the Associate Chief Counsel (International) relating to international issues on which the Service will not issue letter rulings or determination letters, see Rev. Proc. 2025-7, this Bulletin. For a list of areas under the jurisdiction of the

Commissioner, Tax Exempt and Government Entities Division relating to issues, exempt organizations, plans, or plan amendments on which the Service will and will not issue letter rulings or determination letters, see Rev. Proc. 2025-4 and Rev. Proc. 2025-5, this Bulletin.

.02 Changes.

1. Section 3.01(14), regarding rulings under §§ 61, 451, and 1001, has been modified.
2. Section 3.01(96), regarding rulings under §§ 1001 and 1058, has been modified.
3. Old section 3.01(122), regarding rulings under § 4191, has been removed.
4. Section 4.01(29), regarding rulings under § 355, has been modified.
5. Old sections 5.01(3) and (4) have been removed.

SECTION 2. BACKGROUND, SCOPE OF APPLICATION, AND NO-RULE ISSUES PART OF INTEGRATED TRANSACTION

.01 Background. Whenever appropriate in the interest of sound tax administration, it is the policy

of the Service to answer inquiries of individuals and organizations regarding their status for tax purposes and the tax effects of their acts or transactions, prior to the filing of returns or reports that are required by the revenue laws. In employee plans matters described in section 5.15 of Rev. Proc. 2025-1, this Bulletin, the Associate Chief Counsel (EEE) may issue letter rulings after the filing of returns or reports that are required by the revenue laws.

There are, however, certain areas in which the Service will not issue rulings or determination letters. These areas are set forth in sections 3, 4, 5, and 6 of this revenue procedure.

Section 3 sets forth those areas in which rulings or determination letters will not be issued. Section 4 sets forth those areas in which rulings or determination letters will not ordinarily be issued. Whenever used in this revenue procedure, “not ordinarily” means that unique and compelling reasons must be demonstrated to justify the issuance of a ruling or determination letter (which may include consequences of the COVID-19 pandemic). Taxpayers contemplating a request for a ruling in any of the areas set forth in section 4 are encouraged to request a pre-submission confer

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ence to consider whether unique and compelling reasons exist. See section 10.07 of Rev. Proc. 2025-1, this Bulletin. Section 5 sets forth those areas in which the Service is temporarily not issuing rulings or determination letters because those matters are under study. Section 6 sets forth areas in which the Service has provided automatic approval procedures in lieu of issuing rulings or determination letters. The Service will not ordinarily issue rulings for these matters when a taxpayer does not qualify for automatic approval.

See Rev. Proc. 2025-1, this Bulletin, particularly section 6, for general instructions and other situations in which the Service will not or ordinarily will not issue letter rulings or determination letters.

With respect to the items listed, revenue rulings or revenue procedures may be published in the Internal Revenue Bulletin from time to time to provide general guidelines regarding the position of the Service.

Additions or deletions to this revenue procedure as well as restatements of items listed will be made by modification of this revenue procedure. Changes will be published as they occur throughout the year and will be incorporated annually in a new revenue procedure published as the third revenue procedure of the year. These lists should not be considered all-inclusive because the Service may decline to issue a letter ruling or a determination letter when appropriate in the interest of sound tax administration (including due to resource constraints) or on other grounds whenever warranted by the facts or circumstances of a particular case. Decisions not to rule on individual cases (as contrasted with those that present significant pattern issues) are not reported in this revenue procedure and will not be added to subsequent revisions.

If the Service determines that it is not in the interest of sound tax administration to issue a letter ruling or determination letter due to resource constraints, it will adopt a consistent approach with respect to taxpayers that request a ruling on the same issue. The Service will also consider adding the issue to the no-rule list at the first opportunity. See section 6.02 of Rev. Proc. 2025-1, this Bulletin.

.02 Scope of Application. This revenue procedure does not preclude the submission of requests for tech

nical advice to the National Office from other offices of the Service.

.03 No-Rule Issues Part of Integrated Transaction.

If it is impossible for the Service to determine the tax consequences of an integrated transaction without knowing the resolution of an issue on which the Service will not issue rulings or determination letters under this revenue procedure involving a part of the transaction or a related transaction, the taxpayer must state in the request to the best of the taxpayer’s knowledge and belief the tax consequences of the no-rule issue. The Service’s ruling or determination letter will state that the Service did not consider, and no opinion is expressed upon, that issue. In appropriate cases, the Service may decline to issue rulings or determination letters on such integrated transactions due to the relevance of the no-rule issue, despite the taxpayer’s representation. See also section 4.02(2) of this revenue procedure.