SERVICE MAKES THREE ADDITIONS TO NO-RULING AREAS.

Rev. Proc. 87-39

SECTION 1. PURPOSE

Rev. Proc. 87-6, 1987-1 I.R.B. 45, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4 of Rev. Proc. 87-6 is entitled "Areas in which Rulings or Determination Letters Will Not Ordinarily Be Issued." The purpose of this revenue procedure is to amplify Rev. Proc. 87-6 by including other areas in which rulings or determination letters will not ordinarily be issued.

SEC. 2. AREAS IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT ORDINARILY BE ISSUED

Rev. Proc. 87-6 is hereby amended by adding to Section 4.01 the following paragraphs:

Section 894. -- Income Affected by Treaty. -- Whether a foreign recipient of payments made by a United States person is ineligible to receive the benefits of a tax treaty between the United States and a foreign country, pursuant to the application of the principles of Rev. Rul. 84-152, 1984-2 C.B. 381, and Rev. Rul. 84-153, 1984-2 C.B. 383.

Section 894. -- Income Affected by Treaty. -- Whether a recipient of payments is or has been a resident of a country that is party to a tax treaty with the United States for purposes of the application of the tax treaty between the United States and that country.

Section 7701. -- Definitions. -- Foreign estate or trust. -- Whether an estate or trust is treated as a nonresident alien for federal income tax purposes.

SEC. 3. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 87-6 is amplified.

SEC. 4. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on file in the National Office on August 10, 1987, the date of its publication, and to all requests received thereafter.