On September 14th, the IRS released Rev. Proc. 2015 43 (the “Rev. Proc.”) announcing new “no-rule” areas with respect to spin offs involving substantial amounts of investment assets, small amounts of active trade or business assets, or elections to be treated as real estate investment trusts (“REITs”) or regulated investment companies (“RICs”). In addition, on September 14th, the Treasury Department and the IRS issued Notice 2015 59 (the “Notice”) announcing that these no-rule areas are under study. The Rev. Proc. applies to all ruling requests submitted on or after September 14th.