Rev. Proc. 82-45

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 3 of Rev. Proc. 82-22 is entitled, Areas In Which Rulings or Determination Letters Will Not Be Issued.

Sec. 2. Procedure

Rev. Proc. 82-22 is hereby amended by adding the following to section 3.02, entitled, General Areas:

Whether, under the common law rules applicable in determining the employer-employee relationship, a professional staffing corporation (loan-out corporation) or the subscriber is the employer of individuals if:

(a) the loan-out corporation hires employees of the subscriber and assigns the employees back to the subscriber, or;

(b) the loan-out corporation assigns individuals to subscribers for more than a temporary period (one year or longer).

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on July 26, 1982, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

Sec. 4. Effect on Other Revenue Procedures

Rev. Proc. 82-22 is amplified.