"[W]hile there may be a small number of these rulings still 'in the pipeline' that may be completed, after that the IRS is unlikely to consider issuing any more. The normal procedure -- where, as in the case of de-risking, there is ongoing demand for more rulings -- is for IRS to issue a Revenue Ruling similar to the previous Private Letter Rulings... The current controversy over de-risking, however, makes it unlikely that IRS will issue such a Revenue Ruling in this case. In at least two states, Connecticut and New York, legislation has been introduced that, if adopted, would significantly restrict de-risking transactions."  MORE >>