Rev. Proc. 2016-45, issued by the IRS today, modifies Rev. Proc. 2016-3, which sets forth areas on which the IRS will not issue letter rulings or determination letters, by removing two no-rule areas relating to distributions of stock of controlled corporations under section 355. The two areas that are no longer no-rule areas are significant legal issues relating to (i) the corporate business purpose requirement; and (ii) the device test.