Re: a letter ruling:
If you go this route PLEASE have competent counsel write up the filing. It isn't required but you using sloppy language could result in FinCEN ruling based on a yet still flawed understanding of what economic activity is really occurring. The bad news is flawed or not those AR will hurt future AR and court cases.
plussity plus plus. Please don't do this alone. Remember that at this early stage of the game, every ruling is precedent.