SECTION 8. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests postmarked or, if not mailed, received by the IRS after September 29, 2025. If a ruling request described in section 3.01 or 4.01 of this revenue procedure is pending on such date, the taxpayer may consider a supplemental submission with the representations, information, and analysis described in sections 3.04 and 4.03 of this revenue procedure (to the extent this material has not been submitted).