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 · Historical Active
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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 taxpayerÂs first taxable year beginning after December 31, 2004 (the taxpayerÂs 2005 taxable year); or (b) a taxpayerÂs taxable year immediately following the taxpayerÂs 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 taxpayerÂs 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 taxpayerÂs 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 USC 6103
Name of Law: Confidentiality and disclosure of returns and return information
US Code:
44 USC 3507
Name of Law: Public information collection activities; submission to
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
RP-135718-06 SF-83 SUPPORTING STATEMENT.doc
RP-2006-42.pdf
Revenue Procedure Granting Automatic Consent to change certain elections relating to the apportionment of interest expense and research and experimental expenditures