SECTION 5. EFFECTIVE DATE

This revenue procedure is generally effective for taxable years beginning after December 31, 2007. Taxpayers may elect to apply retroactively the provisions of Section 1.482–9T of the temporary regulations to certain taxable years. See Temp. Treas. Reg. §1.482–9T(n)(1). In the case of a valid election, this revenue procedure would also apply to the taxable years subject to such an election.