SECTION 1. PURPOSE.

This revenue procedure prescribes the applicable procedures for the repatriation of cash by a taxpayer via an interest-bearing account receivable or payable (the “account”) in an amount corresponding to the amount allocated to, or from, such taxpayer under section 482 of the Internal Revenue Code (the “Code”) from, or to, a related person. Under this revenue procedure, taxpayers whose income has been adjusted under section 482 of the Code are generally permitted to make certain adjustments to conform their accounts to reflect the section 482 allocation. The conditions for treatment under this revenue procedure are set forth in section 3, the adjustments to be made or allowed are described in section 4 (for Internal Revenue Service as well as taxpayer-initiated adjustments), and the prescribed procedures are set forth in section 5.