IRS WILL NOT ISSUE ADVANCE RULINGS ON WHETHER INCOME IS EFFECTIVELY CONNECTED WITH BUSINESS WITHIN THE U.S

Rev. Proc. 85-7

SECTION 1. BACKGROUND

Rev. Proc. 84-22, 1984-1 C.B. 449, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4 of Rev. Proc.; 84-22 is entitled "Areas In Which Rulings Or Determination Letters Will Not Ordinarily Be Issued."

SEC. 2. PURPOSE

Rev. Proc. 84-22 is hereby amended by amplifying section 4.01.18 to read as follows:

Section 864.--Definitions.--Whether a taxpayer is engaged in trade or business within the United States and whether income is effectively connected with the conduct of a trade or business within the United States.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on February 11, 1985, 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. 84-22 is amplified.