SECTION 4. APPLICATION

.01 Corporation required to complete Schedule M–3 for a taxable year ending on or after December 31, 2004 . For a taxable year ending on or after December 31, 2004, a corporation required to file Schedule M–3 that completes and files Schedule M–3 (in accordance with the instructions

2004–31 I.R.B. 140 August 2, 2004

54.6011–4, or 56.6011–4 with respect to a transaction described in one or more of §§ 1.6011–4(b)(2), (b)(3), (b)(4), (b)(5), or (b)(7), even if the transaction also is described under § 1.6011–4(b)(6).

.06 The Service and the Treasury will continue to evaluate whether the disclosure requirements described in this revenue procedure and Schedule M–3 provide the Service and Treasury adequate information regarding significant book-tax differences.