On 2 January 2019, the US Internal Revenue Service (IRS) issued Revenue Procedure 2020-7 with its updated list of international tax issues on which it will not accept applications for private letter rulings and determination letters.
Revenue Procedure 2020-7 includes two lists of international no-ruling areas, i.e. (i) areas in which rulings or determination letters will not be issued, and (ii) areas in which rulings or determination letters will "not ordinarily be issued".
Inclusion of an item on the "not ordinarily be issued" list means that the IRS will not issue a private letter ruling or determination letter on the issue absent unique and compelling reasons given by the taxpayer that would justify a ruling or determination letter.
Revenue Procedure 2020-7 became effective on 2 January 2020.
Revenue Procedure 2020-7 has been issued as part of the IRS's annual series of revenue procedures for obtaining guidance from the IRS National Office with respect to the tax treatment of specific transactions.