SECTION 4. EFFECTIVE DATE

.01 This revenue procedure is effective for taxable years beginning on or after July 25, 2005. .02 Taxpayers may elect to apply this revenue procedure for any open taxable year beginning after October 6, 1994, but before July 25, 2005. Such election shall be effective for the taxable year of the election and all subsequent open taxable years.

.03 Although this revenue procedure is generally effective for taxable years as stated in §§ 4.01 and 4.02 of this revenue procedure, § 1.482–1(g)(4) of the regulations is generally effective for taxable years beginning after October 6, 1994 (or for earlier open taxable years pursuant to an election under § 1.482–1(j)(2) of the

July 25, 2005 143 2005–30 I.R.B.