SECTION 8. DRAFTING

INFORMATION

The principal author of this revenue procedure is Richard L. Chewning of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure, contact Richard L. Chewning at (202) 622–3850 (not a toll-free call).

(2) The statement referred to in § 4.02(1) of this revenue procedure shall provide as follows:

(i) INTEREST EXPENSE FROM FAIR MARKET VALUE METHOD. “For the immediately preceding taxable year, [name of taxpayer] valued assets for purposes of interest expense apportionment using the fair market value method. Pursuant to Rev. Proc. 2006–42, [name of taxpayer] is changing from the fair market value method to the tax book value

[alternative tax book value] method of asset valuation. This change to the tax book value [alternative tax book value] method applies beginning with [name of taxpayer]’s [XXXX] taxable year,”

(ii) INTEREST EXPENSE FROM ALTERNATIVE TAX BOOK VALUE METHOD. “For the immediately preceding taxable year, [name of taxpayer] valued assets for purposes of interest expense apportionment using the alternative tax book value method. Pursuant to Rev. Proc. 2006–42, [name of taxpayer] is revoking its election to determine tax book value using the alternative tax book value method. This change to the tax book value method applies beginning with [name of taxpayer]’s [XXXX] taxable year,” and/or

(iii) R&E EXPENSE. “For the immediately preceding taxable year, [name of taxpayer] apportioned R&E expense using the sales method as described in § 1.861–17(c)

[one of the optional gross income methods as described in § 1.861–17(d)]. Pursuant to Rev. Proc. 2006–42, [name of taxpayer] is changing from the sales method

[one of the optional gross income methods] to one of the optional gross income methods [sales method]. This change applies beginning with [name of taxpayer]’s

[XXXX] taxable year.

.03 DOCUMENTATION. Any taxpayer that changes methods under this revenue procedure must maintain all documentation necessary to establish its change in method or methods and its eligibility for the benefits of this revenue procedure.