Rev. Proc. 81-8

Section 1. Background

Rev. Proc. 80-22, 1980-1 C.B. 654, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 80-22 is entitled, Areas Under Extensive Study in Which Rulings or Determination Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of a Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

Sec. 2. Procedure

Rev. Proc. 80-22 is hereby amplified by adding the following to section 5:

.06 Section 7701--Definition. Whether a trust that is beneficially owned by the shareholders of the settlor corporation is a trust for federal income tax purposes if the corporation remains in existence after the transfer in trust, and if the corporation retains working interests in oil, gas, or mineral properties, the royalty interests of which properties are transferred to the trust.

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on March 9, 1981, 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. 80-22 is amplified.