FATCA Issue Added to IRS No Rulings List

The Internal Revenue Service has recently released Rev. Proc. 2015-7, which lists issues that letter rulings and determination letters will not be issued for. Newly added section 4.01(27) states that a ruling or letter “will not ordinarily be issued” on “[w]hether a taxpayer, withholding agent, or intermediary has properly applied the requirements of chapter 4 of the Internal Revenue Code (sections 1471 through 1474, also known as “FATCA”) or of an applicable intergovernmental agreement to implement FATCA.”