SECTION 4. SCOPE

This revenue procedure applies to any person required to file Form 8023 to make a valid election under § 338 (hereafter referred to as a required filer) that has not filed Form 8023 by its due date. In the case of a controlled foreign purchasing corporation described in § 1.338–2(e)(3) of the Income Tax Regulations (which, in certain circumstances, permits the United States shareholders of the purchasing corporation, in lieu of the purchasing corporation itself, to file Form 8023), the person that files Form 8023 will be considered the required filer for purposes of this revenue procedure. If more than one person must file Form 8023 for a particular election (for example, an election under § 338(h)(10)), each required filer must comply with this revenue procedure for any required filer to obtain an extension of time to make the election.