Rev. Proc. 74-36

Rev. Proc. 69-19, 1969-2 C.B. 301, sets forth the conditions or circumstances under which, for purposes of advance rulings under section 367 of the Internal Revenue Code of 1954, the Internal Revenue Service will issue a ruling that an agreement that purports to furnish technical "know-how" to a foreign corporation in exchange for stock of such corporation as a transfer of property within the meaning of section 351. Rev. Proc. 69-19 is also applicable with regard to advance rulings requested on this matter where the transferee is a domestic corporation. Furthermore, Rev. Proc. 69-19 is applicable to a request for a ruling that the transfer of "computer software" is a transfer of property within the meaning of section 351.

Rev. Proc. 69-19 is amplified.