IRS WILL NOT ISSUE GUIDANCE ON 'CORPORATE COMBINING TRANSACTIONS'; REV. PROC. 96-3 MODIFIED.

Rev. Proc. 96-22

SECTION 1. PURPOSE

This revenue procedure amplifies and modifies Rev. Proc. 96-3, 1996-1 I.R.B. 82, which sets forth areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Domestic) and the Associate Chief Counsel (Employee Benefits and Exempt Organizations) relating to issues on which the Internal Revenue Service will not issue advance letter rulings or determination letters.

SECTION 2. BACKGROUND

In Rev. Proc. 94-76, 1994-2 C.B. 825, currently reflected in section 5.15 of Rev. Proc. 96-3, the IRS stated that while it was studying whether certain transactions qualifying as corporate reorganizations under section 368 circumvent the purposes of General Utilities repeal, the IRS would not issue advance rulings on the tax consequences of the transactions under study. In notice 96-6, the IRS announced that this study is being closed.

SECTION 3. PROCEDURE

Rev. Proc. 96-3 is amplified by adding to section 3 (Areas In Which Rulings Or Determination Letters Will Not Be Issued) the provision presently in section 5.15, and is modified by deleting the provision from section 5 (Areas Under Extensive Study).

DRAFTING INFORMATION

For further information regarding this revenue procedure, contact Keith Stanley of the Office of Assistant Chief Counsel (Corporate) at (202) 622-7530 (not a toll-free call).