Ruling requests

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In Revenue Procedure 2002-75, the Service indicated that,

we will now consider ruling requests regarding the proper tax treatment of a captive insurance company.

However, some questions are arising in the context of a captive ruling request are so inherently factual (within the meaning of section 4 .02(1) of Rev. Proc. 2002-3) that contact should be made with the appropriate Service function prior to the preparation of such request to determine whether the Service will issue the requested ruling.

Inquiries regarding whether the Service considers a proposed captive transaction so inherently
factual that it cannot rule, should be directed to Chief, Branch 4 , Office of the Associate Chief Counsel (Financial Institutions & Products) at (202) 622-3970 (not a toll-free call).