SECTION 3. APPLICATION

This revenue procedure applies to (1) all requests to obtain the Service’s consent to treat some or all intercompany transactions on a separate entity basis under § 1.1502–13(e)(3), (2) all revocations of such consent, whether the revocation is made by the consolidated group or by the Service, and (3) all requests to obtain the Service’s consent to change from separate entity reporting to single entity reporting in cases where a valid consent from the Service to report intercompany transactions on a separate entity basis was not previously obtained.