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Introduction

SECTION 1. PURPOSE

Internal Revenue Bulletin 2006-47 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure sets forth the administrative procedures for taxpayers described in § 4 of this revenue pro

cedure to obtain automatic approval to change certain elections relating to the apportionment of interest expense under §§ 1.861–8T(c)(2) and 1.861–9(i)(2) and research and experimental expenditures (R&E) under § 1.861–17(e). A taxpayer complying with this revenue procedure will be deemed to have obtained the approval of the Commissioner of the Internal Revenue Service (Commissioner) to change those elections.

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▸Contents — Internal Revenue Bulletin 2006-47
Internal Revenue Bulletin 2006-47

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