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1. Does your request involve an issue under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief
Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief
Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure
and Administration), or the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities)? See section 3 of Rev. Proc. 2004-1, 2004-1 I.R.B. 1. For issues under the jurisdiction of other offices, see section 4 of Rev. Proc. 2004-1. (Hereafter, all references are to Rev. Proc. 2004-1 unless otherwise noted.)
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| Yes No |
2. Have you read Rev. Proc. 2004-3, 2004-1 I.R.B. , and Rev. Proc. 2004-7, 2004-1 I.R.B. , to see if part or all of the request
involves a matter on which letter rulings are not issued or are ordinarily not issued?
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| Yes No N/A |
3. If your request involves a matter on which letter rulings are not ordinarily issued, have you given compelling reasons
to justify the issuance of a letter ruling? Before preparing your request, you may want to call the branch in the Office of
Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions and Products), the Office
of Associate Chief Counsel (Income Tax and Accounting), the Office of Associate Chief Counsel (International), the Office
of Associate Chief Counsel (Passthroughs and Special Industries), the Office of Associate Chief Counsel (Procedure and Administration),
or the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) responsible for substantive
interpretations of the principal Internal Revenue Code section on which you are seeking a letter ruling to discuss the likelihood
of an exception. For matters under the jurisdiction of—
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(a) the Office of Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions and
Products), the Office of Associate Chief Counsel (Income Tax and Accounting), the Office of Associate Chief Counsel (Passthroughs
and Special Industries), or the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities), the
Office of the Associate Chief Counsel (Procedure and Administration), the appropriate branch to call may be obtained by calling
(202) 622-7560 (not a toll-free call);
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(b) the Office of the Associate Chief Counsel (International), the appropriate branch to call may be obtained by calling
(202) 622-3800 (not a toll-free call).
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| Yes No N/A Page |
4. If the request deals with a completed transaction, have you filed the return for the year in which the transaction was
completed? See section 5.05.
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| Yes No |
5. Are you requesting a letter ruling on a hypothetical situation or question? See section 6.11.
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| Yes No |
6. Are you requesting a letter ruling on alternative plans of a proposed transaction? See section 6.11.
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| Yes No |
7. Are you requesting the letter ruling for only part of an integrated transaction? See sections 6.03 and 7.01(1).
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| Yes No |
8. Are you requesting the letter ruling for a business, trade, industrial association, or similar group concerning the application
of tax law to its members? See section 6.05.
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| Yes No |
9. Are you requesting the letter ruling for a foreign government or its political subdivision? See section 6.06.
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| Yes No Pages |
10. Have you included a complete statement of all the facts relevant to the transaction? See section 7.01(1).
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| Yes No N/A |
11. Have you submitted with the request true copies of all wills, deeds, and other documents relevant to the transaction,
and labeled and attached them in alphabetical sequence? See section 7.01(2).
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| Yes No N/A |
12. Have you submitted with the request a copy of all applicable foreign laws, and certified English translations of documents
that are in a language other than English or of foreign laws in cases where English is not the official language of the foreign
country involved? See section 7.01(2).
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| Yes No Pages |
13. Have you included, rather than merely incorporated by reference, all material facts from the documents in the request?
Are they accompanied by an analysis of their bearing on the issues that specifies the document provisions that apply? See section 7.01(3).
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| Yes No Page |
14. Have you included the required statement regarding whether the same issue in the letter ruling request is in an earlier
return of the taxpayer or in a return for any year of a related taxpayer? See section 7.01(4).
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| Yes No Page |
15. Have you included the required statement regarding whether the Service previously ruled on the same or similar issue for
the taxpayer, a related taxpayer, or a predecessor? See section 7.01(5)(a).
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| Yes No Page |
16. Have you included the required statement regarding whether the taxpayer, a related taxpayer, a predecessor, or any representatives
previously submitted a request (including an application for change in accounting method) involving the same or similar issue
but withdrew the request before the letter ruling or determination letter was issued? See section 7.01(5)(b).
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| Yes No Page |
17. Have you included the required statement regarding whether the taxpayer, a related taxpayer, or a predecessor previously
submitted a request (including an application for change in accounting method) involving the same or similar issue that is
currently pending with the Service? See section 7.01(5)(c).
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| Yes No Page |
18. Have you included the required statement regarding whether, at the same time as this request, the taxpayer or a related
taxpayer is presently submitting another request (including an application for change in accounting method) involving the
same or similar issue to the Service? See section 7.01(5)(d).
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| Yes No N/A Page |
19. If your request involves the interpretation of a substantive provision of an income or estate tax treaty, have you included
the required statement regarding whether the tax authority of the treaty jurisdiction has issued a ruling on the same or similar
issue for the taxpayer, a related taxpayer, or a predecessor; whether the same or similar issue is being examined, or has
been settled, by the tax authority of the treaty jurisdiction or is otherwise the subject of a closing agreement in that jurisdiction;
and whether the same or similar issue is being considered by the competent authority of the treaty jurisdiction? See section 7.01(6).
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| Yes No N/A Page |
20. If your request is for recognition of Indian tribal government status or status as a political subdivision of an Indian
tribal government, does your request contain a letter from the Bureau of Indian Affairs regarding the tribe’s status? See section 7.01(7), which states that taxpayers are encouraged to submit this letter with the request and provides the address
for the Bureau of Indian Affairs.
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| Yes No Pages |
21. Have you included the required statement of relevant authorities in support of your views? See section 7.01(8).
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| Yes No Page |
22. Have you included the required statement regarding whether the law in connection with the request is uncertain and whether
the issue is adequately addressed by relevant authorities? See section 7.01(8).
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| Yes No Pages |
23. Does your request discuss the implications of any legislation, tax treaties, court decisions, regulations, notices, revenue
rulings, or revenue procedures that you determined to be contrary to the position advanced? See section 7.01(9), which states that taxpayers are encouraged to inform the Service of such authorities.
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| Yes No N/A Page |
24. If you determined that there are no contrary authorities, have you included a statement to this effect in your request?
See section 7.01(9).
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| Yes No N/A Page |
25. Have you included in your request a statement identifying any pending legislation that may affect the proposed transaction?
See section 7.01(10).
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| Yes No |
26. Is the request accompanied by the deletions statement required by § 6110? See section 7.01(11).
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| Yes No Page |
27. Have you (or your authorized representative) signed and dated the request? See section 7.01(12).
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| Yes No N/A |
28. If the request is signed by your representative or if your representative will appear before the Service in connection
with the request, is the request accompanied by a properly prepared and signed power of attorney with the signatory’s name
typed or printed? See section 7.01(14).
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| Yes No Page |
29. Have you included, signed, and dated the penalties of perjury statement in the format required by section 7.01(15)? |
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| Yes No N/A |
30. Are you submitting your request in duplicate if necessary? See section 7.01(16).
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| Yes No N/A Pages |
31. If you are requesting separate letter rulings on different issues involving one factual situation, have you included a
statement to that effect in each request? See section 7.02(1).
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| Yes No N/A |
32. If you want copies of the letter ruling sent to more than one representative, does the power of attorney contain a statement
to that effect? See section 7.02(2).
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| Yes No N/A |
33. If you want the original of the letter ruling to be sent to a representative, does the power of attorney contain a statement
to that effect? See section 7.02(2).
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| Yes No N/A |
34. If you do not want a copy of the letter ruling to be sent to any representative, does the power of attorney contain a
statement to that effect? See section 7.02(2).
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| Yes No N/A |
35. If you are making a two-part letter ruling request, have you included a summary statement of the facts you believe to
be controlling? See section 7.02(3).
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| Yes No N/A Page |
36. If you want your letter ruling request to be processed ahead of the regular order or by a specific date, have you requested
expedited handling in the manner required by section 7.02(4) and stated a compelling need for such action in the request?
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| Yes No N/A Page |
37. If you are requesting a copy of any document related to the letter ruling request to be sent by facsimile (fax) transmission,
have you included a statement to that effect? See section 7.02(5).
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| Yes No N/A Page |
38. If you want to have a conference on the issues involved in the request, have you included a request for conference in
the letter ruling request? See section 7.02(6).
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| Yes No |
39. Have you included the correct user fee with the request and is your check or money order in U.S. dollars and payable to
the Internal Revenue Service? See section 15 and Appendix A to determine the correct amount.
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| Yes No N/A Page |
40. If your request involves a personal tax issue and you qualify for the reduced user fee when gross income is less than
$250,000, have you included the required certification? See paragraphs (A)(4)(a) and (B)(1) of Appendix A.
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| Yes No N/A Page |
41. If your request involves a business-related tax issue and you qualify for the reduced user fee when gross income is less
than $1 million, have you included the required certification? See paragraphs (A)(4)(b) and (B)(1) of Appendix A.
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| Yes No N/A Page |
42. If you qualify for the user fee for substantially identical letter rulings, have you included the required information?
See section 15.07(2) and paragraph (A)(5)(a) of Appendix A.
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| Yes No N/A Page |
43. If you qualify for the user fee for a § 301.9100 request to extend the time for filing an identical accounting method
change on a single Form 3115, have you included the required information? See section 15.07(3) and paragraph (A)(5)(c) of Appendix A.
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| Yes No N/A |
44. If your request is covered by any of the checklists, guideline revenue procedures, notices, safe harbor revenue procedures,
or other special requirements listed in Appendix E, have you complied with all of the requirements of the applicable revenue
procedure or notice?
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| Rev. Proc. |
List other applicable revenue procedures or notices, including checklists, used or relied upon in the preparation of this
letter ruling request (Cumulative Bulletin or Internal Revenue Bulletin citation not required).
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| Yes No N/A Page |
45. If you are requesting relief under § 7805(b) (regarding retroactive effect), have you complied with all of the requirements
in section 11.11?
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| Yes No |
46. Have you addressed your request to the attention of the Associate Chief Counsel (Corporate), the Associate Chief Counsel
(Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel
(International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure
and Administration), or the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities), as appropriate?
The mailing address is:
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