SEC. 6. EFFECTIVE DATE

.01 In general. This revenue procedure is effective for taxable years beginning after August 23, 1999.

.02 Election for taxable year including August 23, 1999. A United States taxpayer may elect to apply all of the provisions of this revenue procedure on its U.S. income tax return for its taxable year including August 23, 1999.

.03 Taxpayer-initiated adjustments for taxable years prior to the taxable year in- cluding August 23, 1999. A United States taxpayer that increased or decreased its

taxable income pursuant to section 482 and section 1.482–1(a)(3) for a taxable year prior to the taxable year including August 23, 1999, shall be permitted to apply the principles of Rev. Proc. 65-17, 1965–1 C.B. 833, and its progeny, in accordance with any reasonable interpretation thereof for purposes of conforming accounts to reflect the taxpayer-initiated primary adjustment. The Service considers an interpretation that applies the final revised revenue procedure published in this document or its general principles to be such a reasonable interpretation of Rev. Proc. 65–17.