SECTION 1. PURPOSE

This revenue procedure provides the procedures by which a taxpayer may (1) obtain the consent of the Internal Revenue Service (the “Service”) to treat some or all intercompany transactions on a separate entity basis under §1.1502–13(e)(3) of the Income Tax Regulations, (2) revoke such consent, or have such consent revoked by the Service, and (3) obtain the Service’s consent to change from separate entity reporting to single entity reporting where a valid consent from the Service to report

intercompany transactions on a separate entity basis was not previously obtained.

This revenue procedure modifies and supersedes Rev. Proc. 97–49, 1997–2 C.B. 523.