Rev. Proc. 83-88

SECTION 1. BACKGROUND

Rev. Proc. 83-22, 1983-1 C.B. 680, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 83-22 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. 83-22 is hereby amended by adding to section 5 the following new section:

Section 1248-Gain From Certain Sales or Exchanges of Stock In Certain Foreign Corporations.-Whether the earnings and profits of a controlled foreign corporation attributable to stock exchanged in a transaction subject to section 1248 should be reduced by the amount of gain treated as a dividend in the hands of the seller under section 1248(a).

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on December 19, 1983, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as the requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-22 is amplified.