The IRS has revised a chief counsel notice (CC-2016-009) from June 30, indicating that any case in exam or litigation raising an issue under section 385 requires review by an Associate office or the Special Counsel to the National Taxpayer Advocate.  Previously, the IRS required review for issues involving section 385(c), which is limited to whether it is binding when an instrument is characterized as debt at the time of its issuance.  The updated requirements expand the review requirement to issues involving sections 385(a) and (b).