SECTION 4. ADDITIONAL APPLICATION AND PROCEDURES

.01 Ruling requests to which procedures apply.

The procedures described in section 4.02 of this revenue procedure apply to a request for rulings for a Section 355 Transaction. For purposes of this section 4, any defined term has the meaning provided in section 2 of the Appendix to Rev. Proc. 2017-52.

.02 Procedures .

In a request for rulings described in section 4.01 of this revenue procedure, the taxpayer should submit the documentation, factual information, legal analysis, and representations set forth in Rev. Proc. 2025-1 and Rev. Proc. 2017-52. In addition, the taxpayer should submit the representations described in section 4.03 of this revenue procedure.

.03 Representations, information, and analysis.

The representations, information, and analysis described in paragraphs (1) through (6) of this section 4.03 should be submitted. With respect to these representations, the taxpayer should follow the procedures in section 3.04 of Rev. Proc. 2017-52.

(1) Control requirements . Submit the following REPRESENTATIONS: In the Distribution, Distributing will distribute on the same day all the stock and securities of Controlled that it holds immediately before the Distribution. No indebtedness owed by Controlled to Distributing after the Distribution will constitute stock or securities of Controlled or any other entity.

(2) Section 357(b) . Submit the following REPRESENTATION: Any Liabilities assumed (within the meaning of § 357(d)) by Controlled were incurred in the ordinary course of business and are associated with any assets transferred.

(3) Sections 357(c) and 361(b)(3) . Submit the following REPRESENTATION: The total adjusted basis and the fair market value of assets transferred by Distributing to Controlled will each equal or exceed the sum of (a) the total amount of the Liabilities assumed (within the meaning of § 357(d)) by Controlled, and (b) the total amount of any money and the fair market value of other property, if any, received by Distributing and transferred to its shareholders and its creditors .

(4) Sections 361(b)(3) and (c)(3) . Submit the following REPRESENTATION: Any Other Property issued or transferred by Controlled to Distributing in pursuance of the plan of reorganization will be transferred by Distributing to its shareholders in pursuance of the plan of reorganization or to its creditors in connection with the reorganization .

(5) Controlled securities . Submit the following REPRESENTATION: Any securities issued by Controlled to Distributing in pursuance of the plan of reorganization will be transferred by Distributing to its shareholders in pursuance of the plan of reorganization or to its creditors in connection with the reorganization .

(6) Solvency of Distributing and Controlled . Submit the following REPRESENTATION: Immediately after the transaction, the fair market value of the assets of each of Distributing and Controlled will exceed the amount of its Liabilities .