GSTT ISSUE IS ADDED TO IRS NO-RULE LIST.

Rev. Proc. 95-50

SECTION 1. BACKGROUND

Rev. Proc. 95-3, 1995-1 C.B. 385, sets forth areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Domestic) in which the Internal Revenue Service will not issue advance rulings or determination letters. Section 5 of Rev. Proc. 95-3 lists areas under extensive study in which rulings or determination letters will not be issued.

SECTION 2. PROCEDURE

Rev. Proc. 95-3 is amplified by adding to section 5 the following: Section 2601. -- Generation-Skipping Transfer Tax Imposed. -- Whether a trust that is excepted from the application of the generation-skipping transfer tax because it was irrevocable on September 25, 1985, will lose its excepted status if the situs of the trust is changed from the United States to a situs outside of the United States.

SECTION 3. EFFECTIVE DATE.

This revenue procedure applies to all ruling requests pending in the National Office as of December 11, 1955 [sic], and ruling requests received after that date.

SECTION 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 95-3 is amplified.

DRAFTING INFORMATION

The principal author of this revenue procedure is Esther M. Woodworth of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, contact Ms. Woodworth on (202) 622-3090 (not a toll-free call).