SECTION 4. TIME AND MANNER IN

WHICH REQUESTS FOR CONSENT UNDER SECTION 1.1502–13(e)(3) MUST BE FILED

.01 Requests for consent under § 1.1502–13(e)(3) must be filed with the Service on or before the due date of the consolidated return (not including extensions of time) for the first taxable year for which the consent would apply (the “consent year”). These requests for consent must be submitted as a private letter ruling request, and not as a request for change in method of accounting, pursuant to Rev. Proc. 2009–1, or its successor. All applicable items of information listed in section 5 must be included in the request.

.02 The filing requirement of § 1.1502–13(e)(3) will be deemed satisfied where the request for consent is timely filed with the Service and contains all available information. The request must provide an explanation of any omitted information, and state that the omitted information will be submitted not later than the earlier of the following two dates: (1) 90 days after the original due date of the return, or (2) the date the consolidated return is filed with the Service Center.