Revenue Procedure Granting Automatic Consent to change certain elections relating to the apportionment of interest expense and research and experimental expenditures.
ICR 200704-1545-039
OMB: 1545-2040
Federal Form Document
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Revenue Procedure Granting
Automatic Consent to change certain elections relating to the
apportionment of interest expense and research and experimental
expenditures.
Extension without change of a currently approved collection
This revenue procedure provides the
administrative procedure under which a taxpayer may obtain
automatic consent to change (a) from the fair market value method
under §1.861-8T(c)(2) or from the alternative tax book value method
under §1.861-9(i)(1) to apportion interest expense or (b) from the
sales method or the optional gross income methods under
§1.861-17(c) and (d) to apportion research and experimental
expenditures. This revenue procedure is effective for either (a) a
taxpayers first taxable year beginning after December 31, 2004
(the taxpayers 2005 taxable year); or (b) a taxpayers taxable
year immediately following the taxpayers 2005 taxable year, but,
in such case, a taxpayer will not be provided automatic consent to
change any election that first took effect with respect to the
taxpayers 2005 taxable year. This revenue procedure is effective
only if the taxpayer attaches the statement(s) to Form 1118 or Form
1116, whichever is applicable, by the later of (a) one year after
the date this revenue procedure is published, or (b) the due date
(including extensions) of the taxpayers income tax return to which
the statement(s) relates; and if the taxpayer maintains all
necessary documentation to establish change and qualification. The
reporting and recordkeeping requirements imposed by this revenue
procedure will enable the IRS to identify eligibility to use the
procedure and the years for which the new method or methods is
being adopted.
US Code:
26
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and return information
US Code: 44
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