__ 1 See Rev. Proc. 2016-1, Section 11.04(4) stating that a private letter ruling may be "revoked or modified by the issuance of temporary or final regulations." 2 See, e.g., PLR 200722007, PLR 201113018. 3 See, e.g., PLR 201605005. 4 See, e.g., PLR 200623069, PLR 201430017 ("Furthermore, you state that the [CFC] will derive at least 95 percent of its income for passive investments within the meaning of [Section] 954(c)(1)(A), which defines 'personal holding company income' as the portion of gross income which consists of dividends, interest, royalties, rents, and annuities. Accordingly, [subpart F] income received from the [CFC] will be dividend income and therefore will be excluded from the computation of UBTI under [Section] 512(b)(1).")