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26 CFR 601.201: Rulings and determination letters.
SECTION 1. PURPOSE AND NATURE OF CHANGES
.01 The purpose of this revenue proccdure is to update Rev. Proc. 2004-3, 2004-1 C.B. 114, 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 and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue 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. 2005-7, this Bulletin. For a list of areas under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, relating to issues, plans or plan amendments on which the Service will not issue letter rulings or determination letters, see, respectively, section 8 of Rev. Proc. 2005-4 (this Bulletin) and section 3.02 of Rev. Proc. 2005-6 (this Bulletin).
.02 Changes.
(1) New section 3.01(2) (Section 61-Gross Income Defined) has been added.
(2) Section 3.01(14) (section 121-Exclusion of Gain from Sale of Principal Residence) has been modified by deleting reference to former § 1034.
(3) Section 3.01(46) dealing with former § 1034 has been deleted.
(4) New section 5.02 (Section 409A-Inclusion in Gross Income of Deferred Compensation Under Nonqualified Deferred Compensation Plans) has been added.
(5) New sections 5.07, 5.08, and 5.09 (Sections 2036; 2038; and 2041-Transfers with Retained Life Estate, Revocable Transfers, and Powers of Appointment) have been added.
(6) New section 5.10 (Section 6050P-Returns Relating to the Cancellation of Indebtedness by Certain Entities) has been added.
(7) Section 6.01 has been clarified to refleet that the extension provided by Rev. Proc. 2003-33, 2003-1 C.B. 803, is not limited to 12 months and that its applicability is limited to certain taxpayers.
(8) Section 6.02 (Section 442.-Change of Annual Accounting Period) has been revised and updated to include current automatic approval procedures.
(9) Section 6.03 has been revised to provide a...