SECTION 3. SIGNIFICANT CHANGES

Significant changes to Rev. Proc. 2000–11 made by this revenue procedure include:

.01 Section 4.01(1) of this revenue procedure provides that this revenue procedure is the exclusive procedure for corporations within its scope to change their annual accounting period;

.02 Section 4.01(2) of this revenue procedure waives only certain scope restrictions for changes to (or from) a 52–53-week taxable year that references the same calendar month;

.03 Section 4.01(3) of this revenue procedure provides that a corporation that wants to change to or retain a natural business year that satisfies the 25-percent gross receipts test described in section 5.05 of this revenue procedure, or to a 52–53-week taxable year ending with reference to such taxable year, may do so under this revenue procedure notwithstanding certain of the limitations imposed under section 4.02;

.04 Section 4.02(1) of this revenue procedure reduces the period of time required between a prior accounting period change and a change effected under this revenue procedure from 6 calendar years to 48 months;

.05 Section 4.02(1) of this revenue procedure also adds to the list of accounting period changes that will not be considered prior changes for purposes of the 48-month rule: (a) a change to comply with § 1.1502–75, (b) any prior change made by a corporation whose majority shareholder has changed its taxable year within the last 12 months if the corporation wants to change to that shareholder’s taxable year in order to file consolidated

financial statements, and (c) a change to a required taxable year or an ownership taxable year;

.06 Section 4.02(2) of this revenue procedure adds to the list of corporations with certain pass-through interests that are ineligible to use this revenue procedure certain shareholders of a closelyheld REIT;

.07 Section 4.02(2) of this revenue procedure also incorporates into this list of potentially prohibited pass-through interests an interest in a controlled foreign corporation (CFC), foreign personal holding company (FPHC), or passive foreign investment company (PFIC) and, as a result, allows an exception for de minimis interests in these entities;

.08 Section 4.02(2)(b) of this revenue procedure provides that, in certain cases in which a partnership is owned 50-percent by each of two partners, the corporate partner’s interest in the partnership will be disregarded;

.09 Section 4.02(8) of this revenue procedure provides an exception to the scope restrictions for a CFC or FPHC that wants to change to its required taxable year;

.10 Section 4.02(12) of this revenue procedure adds to the list of corporations ineligible to use this revenue procedure a corporation not otherwise described in this revenue procedure that has a required taxable year, unless that corporation is changing to its required taxable year;

.11 Section 6.04 of this revenue procedure now provides certain exceptions to the record keeping/book conformity rule; and

.12 Section 6.08 of this revenue procedure adds a term and condition to prevent the carryback of capital losses generated in the short period.