SECTION 5. MODIFICATIONS TO REVENUE PROCEDURE 2025-1

Rev. Proc. 2025-1 is modified as follows with respect to requests for private letter rulings postmarked or, if not mailed, received by the IRS after, September 29, 2025:

.01 Section 7.01(2)(a) .

(1) First paragraph . Section 7.01(2)(a) of Rev. Proc. 2025-1 is modified by deleting the second sentence of the first paragraph and adding the following in its place:

But see section 3.02 of Rev. Proc. 2017-52, 2017-41 I.R.B. 283, and sections 3.03 and 4.02 of Rev. Proc. 2025-30, 2025-42 I.R.B. 489, for requirements relating to ruling requests under § 355.

(2) Second paragraph . Section 7.01(2)(a) of Rev. Proc. 2025-1 is further modified by deleting the second paragraph and adding the following in its place:

If the request concerns a corporate distribution, reorganization, or similar transaction, the corporate balance sheet and profit and loss statement also should be submitted. If the request relates to a prospective transaction, the most recent balance sheet and profit and loss statement should be submitted. See section 3.02 of Rev. Proc. 2017-52, and sections 3.03 and 4.02 of Rev. Proc. 2025-30, for requirements relating to ruling requests under § 355.

.02 Appendix F . Section .01 of Appendix F to Rev. Proc. 2025-1 is modified as follows:

(1) In the column titled REVENUE PROCEDURE AND NOTICE, in the text corresponding to “Subchapter C—Corporate Distributions, Adjustments, Transfers, and Reorganizations” found in the column CODE OR REGULATION SECTION, by deleting the text and adding the following text in its place:

Rev. Proc. 77-37, 1977-2 C.B. 568, as amplified by Rev. Proc. 77-41, 1977-2 C.B. 574, and Rev. Proc. 83-81, 1983-2 C.B. 598, and as modified by Rev. Proc. 89-30, 1989-1 C.B. 895 ( see also Rev. Proc. 2025-3, this Bulletin), Rev. Proc. 84-42, 1984-1 C.B. 521 (superseded, in part, as to no-rule areas by Rev. Proc. 2018-3), Rev. Proc. 86-42, 1986-2 C.B. 722, Rev. Proc. 89-50, 1989-2 C.B. 631, Rev. Proc. 2017-52, 2017-41 I.R.B. 283, and Rev. Proc. 2025-30, 2025-42 I.R.B. 489.

(2) In the column titled REVENUE PROCEDURE AND NOTICE, in the text corresponding to “355 Checklist questionnaire” found in the column CODE OR REGULATION SECTION, by deleting the text and adding the following text in its place:

Rev. Proc. 2017-52, 2017-41 I.R.B. 283, and Rev. Proc. 2025-30, 2025-42 I.R.B. 489.