Realignment of TE/GE shifts preparation of certain technical guidance involving plans to Office of Chief Counsel

The IRS has addressed the transfer of certain technical responsibility for issues involving qualified retirement plans, individual retirement annuities and accounts (IRAs), and exempt organizations to the Office of Chief Counsel that will occur with the realignment of Tax Exempt/Government Entities Division (TE/GE). As a result of the realignment occurring at the beginning of 2015, the technical responsibility for preparing revenue rulings, revenue procedures, announcements, notices and the issuance of technical advice (including technical advice memoranda), certain letter rulings and certain information letters on matters involving plans, IRAs, and exempt organizations will shift from the Employee Plans office of TE/GE (Employee Plans) and the Exempt Organizations office of TE/GE (Exempt Organizations) to the Office of Associate Chief Counsel (Tax Exempt/Government Entities). The Employee Plans office of TE/GE will retain the authority to issue determination letters and the Exempt Organizations office of TE/GE will retain the authority to issue determination letters, including determination letters on the exempt status of organizations under Code Secs. 501(c) and 521. The authority will shift as of January 2, 2015.

The annual updates of Rev. Proc. 2014-1. Rev. Proc. 2014-2, Rev. Proc. 2014-3, Rev. Proc. 2014-4, and Rev. Proc. 2014-8 will reflect the transfer of authority described in the announcement from TE/GE to Chief Counsel. Aside from minor changes, the realignment will not affect the annual update of Rev. Proc. 2014-6 and Rev. Proc. 2014-9.

As to Rev. Proc. 2014-5, because the authority for issuing all technical advice memoranda (TAMs) will shift to the Office of Associate Chief Counsel January 2015, there will be no revenue procedure covering the issuance of TAMs by TE/GE for years after 2014. Instead, Rev. Proc. 2015-5 will describe the processing of applications for recognition of exemption on Form 1023-EZ (Streamline Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code).

Letter ruling requests submitted to TE/GE before January 2, 2015 that are pending on that date, will be transferred to TE/GE Counsel without the need for the taxpayer that requested the ruling to take any action.

Source: IRS Announcement 2014-34.

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