IRS Publishes List Of Rulings No Longer Determinative.

Rev. Rul. 2005-43

The Internal Revenue Service is continuing its program of reviewing rulings (including revenue rulings and revenue procedures) published in the Internal Revenue Bulletin to identify and publish lists of those rulings that, although not specifically revoked or superseded, are no longer considered determinative.

Rev. Proc. 64-54, 1964-2 C.B. 1008, as extended by Rev. Proc. 66-33, 1966-2 C.B. 1231, pertains to certain unilateral relief in respect of the foreign tax paid on income allocated to a U.S. taxpayer pursuant to section 482.

This revenue ruling publishes a list including Rev. Proc. 64-54 and subsequent rulings relating to Rev. Proc. 64-54 that have been identified under the Internal Revenue Service's review program as not determinative with respect to future transactions because these rulings apply to taxable years beginning before January 1, 1965.

Accordingly, the rulings listed below are hereby declared obsolete.

Ruling No.

Rev. Proc. 64-54 Rev. Rul. 65-109 Rev. Proc. 66-33 Rev. Rul. 68-549 Rev. Proc. 69-13 Rev. Proc. 71-1 Rev. Proc. 72-22

C.B. Citation 1964-2 C.B. 1008 1965-1 C.B. 222 1966-2 C.B. 1231 1968-2 C.B. 202 1969-1 C.B. 402 1971-1 C.B. 658 1972-1 C.B. 747

The Service will continue to review other rulings to ascertain those that are inapplicable to future transactions. Therefore, failure to include any particular ruling in the above list should not be construed as an indication that the ruling necessarily is determinative with respect to future transactions.

DRAFTING INFORMATION

The principal author of this revenue ruling is Thomas A. Vidano of the Office of Associate Chief Counsel (International). For further information regarding this revenue ruling, contact Mr. Vidano at (202) 435-5265 (not a toll-free call).