Annual revenue procedures for 2013; expanded “no-rule list” for corporations 

• Rev. Proc. 2013-1: Letter rulings, information letters, and determination letters—the schedule of user fees for letter rulings is included in Appendix A and reveals that for most requests for letter rulings, the amount of the user fee remain the same
• Rev. Proc. 2013-2: Technical advice
• Rev. Proc. 2013-3: Areas in which rulings will not be issued (domestic areas) (see below for three updates to the “no-rule lists” for corporations)
• Rev. Proc. 2013-4: Rulings and information letters; issuance procedures
• Rev. Proc. 2013-5: Technical advice
• Rev. Proc. 2013-6: Employee plan determination letters
• Rev. Proc. 2013-7: Areas in which rulings will not be issued; Associate Chief Counsel (International)
• Rev. Proc. 2013-8: User fees for employee plans and exempt organizations
• Rev. Proc. 2013-9: Determination letters and rulings (exempt organizations)
• Rev. Proc. 2013-10: Determination letters and rulings on private foundations

Read the revenue procedures and user fee schedules: IRB 2013-1 [PDF 1.99 MB] and IRB 2013-2 [PDF 300 KB]

Expanded “no-rule list” in Rev. Proc. 2013-3

Additions to the “no-rule list” include:

• 5.01(9). Section 355: Whether a corporation is a “controlled corporation” within the meaning of section 355(a)(1)(A) if, in anticipation of a distribution of the stock of the corporation, a distributing corporation acquires putative control of the controlled corporation (directly or through one or more corporations) in any transaction (including a recapitalization) in which stock or securities were exchanged for stock having a greater voting power than the stock or securities relinquished in the exchange, or if in anticipation of a distribution of the stock of the putative controlled corporation, such corporation issues stock to another person having different voting power per share than the stock held by the distributing corporation.
• 5.01(10). Sections 355 and 361: Whether either section 355 or section 361 applies to a distributing corporation’s distribution of stock or securities of a controlled corporation in exchange for, and in retirement of, any putative debt of the distributing corporation if such distributing corporation debt is issued in anticipation of the distribution.
• 5.02(2). Whether transfers of stock, money, or property by a person to a corporation and transfers of stock, money, or property by that corporation to that person (or a person related to such person) in what are ostensibly two separate transactions (i.e., “north-south” transactions), at least one of which is a distribution with respect to the corporation’s stock, a contribution to the corporation’s capital, or an acquisition of stock, are respected as separate transactions for federal income tax purposes.