RP-2015-37

This revenue procedure amplifies Rev. Proc. 2015–3, 2015–1 I.R.B. 129, which sets forth areas of the Internal Revenue Code in which the Internal Revenue Service will not issue letter rulings or determination letters.

Section 5 of Rev. Proc. 2015–3 sets forth a list of those areas of the Internal Revenue Code 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 (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue Service will not issue letter rulings or determination letters until the Service resolves the issue through publication of a revenue ruling, a revenue procedure, regulations, or otherwise.

Rev. Proc. 2015–3 is amplified by adding the following to section 5.01: Section 1014. Basis of Property Acquired from a Decedent. Whether the assets in a grantor trust receive a section 1014 basis adjustment at the death of the deemed owner of the trust for income tax purposes when those assets are not includible in the gross estate of that owner under chapter 11 of subtitle B of the Internal Revenue Code.

Rev. Proc. 2015–3 is amplified.

This revenue procedure is effective for all requests received after June 15, 2015.

The principal author of this revenue procedure is Meghan Howard of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, please contact Ms. Howard at 202-317-5055 (not a toll-free number).